CFM63110 - Foreign exchange: matching: anti-avoidance: FA 2009: 바카라 사이트˜one way exchange effect바카라 사이트™: overview
FA 2009: the 바카라 사이트˜one-way exchange effect provision바카라 사이트™
The Loan Relationships and Derivative Contracts (Disregard and Bringing into Account of Profits and Losses) Regulations 2006 - SI 2006/843) which aimed to counter particular 바카라 사이트˜one-way bet바카라 사이트™ schemes (CFM63010) were revoked by FA09, and replaced by a more widely targeted anti-avoidance rule (바카라 사이트˜TAAR바카라 사이트™), which prevents exchange gains from being matched where a 바카라 사이트˜one-way exchange effect바카라 사이트™ is present. The details of this rule are explained at CFM63120. onwards.
Commencement
The new anti-avoidance rule applies to accounting periods beginning on or after 22 April 2009. Accounting periods straddling 22 April 2009 are treated as if they were two periods, with exchange gains and losses being computed separately for each period. The restriction on matching exchange gains applies to the part-period beginning on 22 April 2009, but not to the earlier part of the accounting period.
The commencement rule at FA09/SCH21/PARA11 also applies to the old regulations so they apply to a part-period up to 22 April 2009, but not subsequently.