Regulation 5 ceases to have effect from 22 April 2009

Regulation 5: option schemes

Regulation 5 counters a disclosed ‘one-way forex bet’ scheme that relies on a disparity of tax treatment between currency options and options over foreign currency denominated treasury bills.

In the scheme, a company (‘Company A’), which accounts in sterling and wishes to hedge its forex exposure in respect of an investment in a subsidiary:

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