{
  "url": "https://openlegislation.uk/corporation-tax-act-2009/section-415",
  "json_url": "https://openlegislation.uk/corporation-tax-act-2009/section-415.json",
  "legislation": "ukpga/2009/4",
  "legislation_title": "Corporation Tax Act 2009",
  "legislation_url": "https://openlegislation.uk/corporation-tax-act-2009",
  "path": "section/415",
  "kind": "section",
  "number": "415",
  "heading": "Loan relationships with embedded derivatives",
  "text": "(1) This section applies if in accordance with generally accepted accounting practice a company treats the rights and liabilities under a loan relationship to which it is a party as divided between—\n(a) rights and liabilities under a loan relationship (“the host contract”), and\n(b) rights and liabilities under one or more derivative financial instruments or equity instruments.\n(2) The company is treated for the purposes of this Part as a party to a loan relationship whose rights and liabilities consist only of those of the host contract.\n(3) For the corresponding treatment of the rights and liabilities within subsection (1)(b), see section 585 (loan relationships with embedded derivatives).",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "C",
      "label": "C1",
      "text": "S. 415 excluded (with effect in accordance with reg. 1(2)(3) of the amending S.I.) by The Taxation of Regulatory Capital Securities Regulations 2013 (S.I. 2013/3209), regs. 1(1), 3(2)(a) (with reg. 8)"
    },
    {
      "type": "C",
      "label": "C2",
      "text": "Pt. 5 modified (with effect in accordance with reg. 1(2)(3) of the amending S.I.) by The Taxation of Regulatory Capital Securities Regulations 2013 (S.I. 2013/3209), regs. 1(1), 11(3)-(6)"
    },
    {
      "type": "C",
      "label": "C3",
      "text": "Pt. 5 modified by 2010 c. 4, s. 676AG(1) (as inserted (with effect in accordance with Sch. 4 para. 190 of the amending Act) by Finance (No. 2) Act 2017 (c. 32), Sch. 4 para. 75)"
    },
    {
      "type": "C",
      "label": "C4",
      "text": "S. 415 applied by 2010 c. 8, s. 493 (as inserted (with effect in accordance with Sch. 5 para. 25(1)-(3) of the amending Act) by Finance (No. 2) Act 2017 (c. 32), Sch. 5 para. 1 (with Sch. 5 paras. 27, 32-34))"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2009/4/section/415",
    "retrieved_at": "2026-10-29T09:11:19.560467+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}