{
  "url": "https://openlegislation.uk/corporation-tax-act-2009/section-648",
  "json_url": "https://openlegislation.uk/corporation-tax-act-2009/section-648.json",
  "legislation": "ukpga/2009/4",
  "legislation_title": "Corporation Tax Act 2009",
  "legislation_url": "https://openlegislation.uk/corporation-tax-act-2009",
  "path": "section/648",
  "kind": "section",
  "number": "648",
  "heading": "Creditor relationships: embedded derivatives which are exactly tracking contracts for differences",
  "text": "(1) This section applies to a derivative contract of a company for an accounting period if each of conditions A to F is met.\n(2) Condition A is that the derivative contract is a relevant contract to which the company is treated as a party under section 585(2) (loan relationships with embedded derivatives) because of a creditor relationship of the company.\n(3) Condition B is that the derivative contract is treated as a contract for differences by section 585(3) (contract treated as option, future or contract for differences).\n(4) Condition C is that the derivative contract is an exactly tracking contract.\n(5) Condition D is that the underlying subject matter of the derivative contract is qualifying ordinary shares listed on a recognised stock exchange.\n(6) Condition E is that the company is not a party to the creditor relationship at any time in the accounting period for the purposes of a trade carried on by it.\n(7) Condition F is that the company is not an excluded body.\n(8) Where this section applies to a derivative contract, the asset representing the creditor relationship is treated for corporation tax purposes as not being a qualifying corporate bond.\n(9) See also section 672 (treatment of net gains and losses on disposal of certain embedded derivatives).",
  "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/648",
    "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."
}