Related Commentary  Related HMRC Manuals

609(1)  If a company ceases to be UK resident, this Part applies as if–

(a)immediately before so ceasing the company had assigned the rights and liabilities under its derivative contracts for consideration of an amount equal to their fair value at that time, and

(b)it had immediately reacquired them for consideration of the same amount.

609(2)  Subsection (1) does not apply in relation to a derivative contract so far as immediately after the company ceases to be UK resident its rights and liabilities under the contract are held or owed–

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