Taxation of Loan Relationships and Derivative Contracts

by David Southern

Overview

Taxation of Loan Relationships and Derivative Contracts, Tenth Edition, is updated in line with the Finance Act 2015 which brings in significant changes to the loan relation rules. In addition, it includes changes to both UK and International Accounting Standards.

This new edition covers developments in the Basic Erosion and Profit Shifting (BEPs) project and the related new climate and wider concept of tax avoidance (GAAR). The chapters covering accounting framework, reorganisations and international aspects have been significantly updated since the previous edition and new chapters have been added with a summary of all relevant cases and a chapter covering Islamic Finance.

Covers the following:
The Taxation of Finance
Accounting under IFRS and Modified UK GAAP
The Scheme of the Legislation
Loan Relationships: Scope and Definition
Loan Relationships: General Computational Provisions
Loan Relationships: Special Computational Provisions
Impairment Losses
Foreign Exchange and Hedging/Deferral
Interest
Securities
Reorganisations, Acquisitions and Disposals
Special Companies
Derivative Contracts – Definition and Scope
Derivative Contracts – Measurement of Profits
Embedded Derivatives
Worldwide Debt Cap
Transfer Pricing
Stock Lending and Repos
International Aspects
Islamic Finance
Cases
Appendices

Product Details

ISBN-13:	9781784511357
Publisher:	Bloomsbury Publishing
Publication date:	01/13/2017
Sold by:	Barnes & Noble
Format:	eBook
Pages:	656
File size:	7 MB

About the Author

David Southern is a Barrister at Temple Gardens Tax Chambers and specialises in corporate finance.
He regularly appears in a wide range of Tax Tribunals and Courts up to and including the European Court of Justice. His advisory work covers most areas of business and personal tax and clients include leading corporates, prominent individuals and political parties.
David Southern KC is a barrister at Field Court Tax Chambers. He specialises in commercial tax, including direct tax, VAT and pension schemes and in all forms of tax litigation, including tax investigations and judicial review

Table of Contents

1 The Taxation of Finance
2 The Accounting Framework
3 The Scheme of the Legislation
4 Loan Relationships: Scope and Definition
5 Loan Relationships: General Computational Provisions
6 Loan Relationships: Special Computational Provisions
7 Impairment Losses
8 Securities
9 Interest
10 Foreign Exchange Gains and Losses
11 Reorganisations, Acquisitions and Disposals
12 Special Companies
13 Derivative Contracts – Definition and Scope
14 Derivative Contracts – Measurement of Profits
15 Embedded Derivatives
16 Hedging and Deferral
17 Case Law
18 Islamic Finance
19 Stock Lending and Repos
20 International Aspects
21 Worldwide Debt Cap
Appendix Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) Regulations 2004