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The Corporation Tax Regime for Property Derivatives

David Boneham of Deloitte describes the corporation tax treatment of property derivatives under the derivative contracts rules.

 
David Boneham of Deloitte describes the corporation tax treatment of property derivatives under the derivative contracts rules.
 
'This article was originally published in Issue 872 (12 February 2007) but has been updated to take into account a change in HMRC interpretation regarding the treatment of certain property derivatives in relation to REITs. This has emerged from the recent finalisation of the HMRC guidance on the taxation of REITs.'
 
Property derivatives were largely excluded when the Government introduced the comprehensive tax regime for derivatives in the Finance Act 2002. The general approach of the regime was to charge profits on derivatives to corporation tax as income following the accounts. Property derivatives were excluded because outside...

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