Tolley's taxation of corporate debt, foreign exchange and derivative contracts

著者

    • Southern, David
    • PricewaterhouseCoopers. Foreign Exchange Tax Team

書誌事項

Tolley's taxation of corporate debt, foreign exchange and derivative contracts

by David Southern and the PricewaterhouseCoopers Foreign Exchange Tax Team

Tolley, c2002

6th ed

大学図書館所蔵 件 / 1

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注記

Previous ed.: 2001

Includes index

内容説明・目次

内容説明

A new regime for monetary transactions was heralded by the three separate tax codes introduced from 1993 to 1996 for foreign exchange, financial instruments and loan relationships. Now the proposals for Finance Act 2002 radically consolidates, extends and recasts the new rules and new anti-avoidance provisions have already taken effect from 26 July 2001. This work has been published in response to the latest legislation, covering the draft proposals in the Inland Revenue Consultation Document of 26 July 2001. The work is an amalgamation of both Tolley's Taxation of Corporate Debt and Financial Instruments and of Tolley's Taxation of Foreign Exchange Gains and Losses. This publication focuses on the practical implications of these provisions and provides comprehensive coverage of the interaction between the tax codes, the accounting framework, corporate transactions and planning issues. Including all the relevant legislation and background information, this essential guide will help you to review, plan and restructure your financial transactions to avoid potential and unexpected tax liabilities.

目次

"Abbreviations and References, Glossary, Tables of Statutes, SIs, EU Directives, EC Treaty Articles, OECD Model Convention and Cases, Introduction, Loan Relationships: scope and definition, Loan Relationships: the charging provisions, Interest and interest equivalents, Structured capital finance, Debt securities, Loan Relationships, general computational provisions, Losses, Loan Relationships, special computational provisions, Reorganisations, acquisitions and disposals, Special companies, Introduction to the taxation of foreign exchange gains and losses, Overview of the 1993 Finance Act foreign exchange tax regime, Foreign exchange within the FA 2002 proposals, Matching foreign exchange gains and losses, Local currency companies - use of currency other than sterling, Derivative contracts, derivative contracts: computation of profits, Collateralised transactions, Anti-avoidance rules, Appendix 1 - Loan note, Appendix 2 - Letter of credit, Appendix 3 - Hansard extract, 29/2/96, Appendix 4 - Convertible loan stock, Appendix 5 - Zero coupon bond, Appendix 6 - ESC 8/8/96, Appendix 7 - Hansard Extract, 28/3/96-Unallowable purpose, Appendix 8 - Derivative contracts, Appendix 9 - FA 1942, s 47, Appendix 10 - Financial formulae and examples, Appendix 11 - BIS Press Release on Tier 1 Capital, Index."

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