CFM39093 - Other rules: Intra-group convertibles: example

CTA09/S418 (repealed)

This guidance applies only in relation to assets held on or before 19 July 2011 and amounts arising up to that date. It was superseded by the {group mismatch scheme provisions CFM77500}.

»Ê¹ÚÌåÓýapp effect of CTA09/S418: example

Companies X and Y are in the same group, but X prepares accounts to 31 December, while Y prepares accounts to 31 March. X issues a convertible security to Y on 1 October 2010.

»Ê¹ÚÌåÓýapp relevant accounting period of X (the debtor) is year ended 31 December 2010. Y’s accounting period year ended 31 March 2011 is a ‘corresponding accounting periodâ€�. (So is year ended 31 March 2010, but clearly Y’s accounts for this period will not contain any credits or debits in respect of this loan relationship).

»Ê¹ÚÌåÓýapp debits brought into account by X in respect of the period 1 October 2010 to 31 December 2010 must, in order to give a just and reasonable result, be compared to the credits arising to Y for the same period. »Ê¹ÚÌåÓýapp relevant credits will therefore be those that would be brought into account by Y, using an effective interest rate method, if its period of account began on 1 October 2010 and ended on 31 December 2010.