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HMRC internal manual

Corporate Finance Manual

Old rules: derivative contracts: basic rules pre FA 2004: connected parties

Connected parties

This guidance applies to periods of account beginning before 1 January 2005

There is nothing in the derivative contract rules which reproduces the effect of FA96/SCH9/PARA6 which provides that no relief is normally given for bad debts nor for any taxation of releases where the parties are connected. Nor is there anything equivalent to FA96/S87, which would require use of an accruals basis by reason of the parties to a derivative contract being connected.