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George Bull
Senior Tax Partner

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T: 020 3201 8000
F: 020 3201 8001

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Tax and Accounting

Our predictions

Forex matching – hedging rules

The imperfect link between tax and accounting at the individual company level has led to opportunities for structuring transactions so as to shift the entire commercial risk to the Exchequer. It has been noted that it is possible to 'over hedge' transactions so that the taxpayer cannot lose and that the Exchequer bears the cost if there is a loss.

Counter avoidance measures are being consulted upon. These will inevitably increase the complexity of the UK tax rules and the level of uncertainty as to the commercial consequences.

Corporation Tax loan relationships and derivative contracts - changes in accounting standards

Proposals by the International Accounting Standards Board (IASB) to amend International Accounting Standard 39 are likely to have a significant impact on the Corporation Tax rules on loan relationships and derivative contracts (Parts 5 to 7 of the Corporation Tax Act 2009. It is anticipated that Finance Bill 2010 will include a regulation-making power to amend these rules.