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HMRC manual changes: 5 April 2024

Direct taxes 

Manual  Page  Comments 
Corporate Finance Manual Updated: CFM51095 The updated guidance refers to ‘derivative contract provisions’ instead of ‘loan relationship provisions’ in the context of relievable pre-commencement derivative contract debits for non-UK resident companies starting a UK property business under section 607ZA of the Corporation Tax Act 2009.
Additionally the latest version introduces guidance on how to apply section 607ZA where an election into the Disregard Regulations SI 2004/3256 is made once the company starts to carry on a UK property business. It states that when applying s 607ZA CTA 2009 in those circumstances it is appropriate to calculate the amount of debits in earlier periods on the assumption that the Disregard Regulations also applied in those periods.


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