{
  "url": "https://openlegislation.uk/corporation-tax-act-2009/section-665",
  "json_url": "https://openlegislation.uk/corporation-tax-act-2009/section-665.json",
  "legislation": "ukpga/2009/4",
  "legislation_title": "Corporation Tax Act 2009",
  "legislation_url": "https://openlegislation.uk/corporation-tax-act-2009",
  "path": "section/665",
  "kind": "section",
  "number": "665",
  "heading": "Introduction to section 666",
  "text": "(1) Section 666 (allowable loss treated as accruing) applies to a company for an accounting period if each of conditions A to F is met.\n(2) Condition A is that the company is treated as a party to a relevant contract under section 585(2) (loan relationships with embedded derivatives) because of a debtor relationship of the company.\n(3) Condition B is that the division mentioned in section 585(1) (loan relationships with embedded derivatives) in the case of the debtor relationship is between—\n(a) rights and liabilities under a loan relationship, and\n(b) rights and liabilities under an equity instrument of the company.\n(4) Condition C is that the relevant contract is treated as an option by section 585(3) (contract treated as option, future or contract for differences).\n(5) Condition D is that the company pays an amount in the accounting period to the person who is a party to the debtor relationship as creditor in discharge of any obligations under that relationship.\n(6) Condition E is that at the time when the company became a party to the debtor relationship—\n(a) it was not carrying on a banking business or a business as a securities house, or\n(b) if it was carrying on such a business, it did not become a party to that relationship in the ordinary course of that business.\n(7) Condition F is that the company is not an excluded body.\n(8) In this section “option” is to be construed as if section 580(2) and (3) (meaning of “option”) were omitted.",
  "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/665",
    "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."
}