{
  "url": "https://openlegislation.uk/corporation-tax-act-2009/section-496",
  "json_url": "https://openlegislation.uk/corporation-tax-act-2009/section-496.json",
  "legislation": "ukpga/2009/4",
  "legislation_title": "Corporation Tax Act 2009",
  "legislation_url": "https://openlegislation.uk/corporation-tax-act-2009",
  "path": "section/496",
  "kind": "section",
  "number": "496",
  "heading": "Meaning of “hedging relationship”",
  "text": "(1) For the purposes of section 494, in relation to an open-ended investment company, a unit trust scheme or an offshore fund, there is a hedging relationship between a derivative contract (“the hedging instrument”) and an asset (“the hedged item”) so far as condition A or B is met.\n(2) Condition A is that the hedging instrument and the hedged item are designated as a hedge by the company, scheme or fund.\n(3) Condition B is that the hedging instrument is intended to act as a hedge of exposure to changes in fair value of a hedged item which is—\n(a) a recognised asset which could affect the total net return of the company, scheme or fund, or\n(b) an identified part of such an asset which is attributable to a particular risk.\n(4) For the purposes of subsection (3) “the total net return” of a company, scheme or fund means its total net return calculated—\n(a) in accordance with generally accepted accounting practice, or\n(b) in the case of accounts prepared in a jurisdiction outside the United Kingdom, in accordance with generally accepted accounting practice in that jurisdiction.",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2009/4/section/496",
    "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."
}