Policy paper

Modernising the taxation of corporate debt and derivative contracts: update

This Tax Information and Impact Note explains the amendments to the Corporation Tax Act 2009 (CTA 09) that apply to groups of companies.



This measure will amend the rules in Chapter 4 of Part 5, and Chapter 5 of Part 7, of the Corporation Tax Act 2009 (CTA 09). The changes will amend the ‘de-grouping’ provisions in those chapters that apply when a company to which a loan relationship or derivative contract has been transferred (a ‘transferee company’) ceases to be a member of the group.

This supports the government’s objective of establishing a simpler, more certain and more robust tax system.

Published 19 March 2014