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HMRC internal manual

Capital Gains Manual

Debts not debts on a security: subsequent creditor: companies

FA93 and FA96

FA93 introduced new rule for the treatment of foreign exchange gains and losses (FOREX) for companies. For accounting periods beginning on or after 23 March 1995, simple debt denominated in foreign currency within the FOREX regime was no longer liable to chargeable gains, see CG44000.

This rule was however repealed by FA96 on the introduction of more general changes to the taxation of debts held by companies with effect from 1 April 1996. From this date, debts within FOREX were excluded from capital gains by the more general rules for loan relationships of companies, see CG54000+.