{
  "url": "https://openlegislation.uk/exchange-gains-and-losses-transitional-provisions-regulations-1994/regulation-12",
  "json_url": "https://openlegislation.uk/exchange-gains-and-losses-transitional-provisions-regulations-1994/regulation-12.json",
  "legislation": "uksi/1994/3226",
  "legislation_title": "The Exchange Gains and Losses (Transitional Provisions) Regulations 1994",
  "legislation_url": "https://openlegislation.uk/exchange-gains-and-losses-transitional-provisions-regulations-1994",
  "path": "regulation/12",
  "kind": "regulation",
  "number": "12",
  "heading": "Assets and liabilities as respects which there is an attributed gain or loss",
  "text": "(1) Subject to regulation 15, in relation to an asset or liability held or owed by a company as respects which—\n(a) there is an attributed gain, E, or an attributed loss, F, and\n(b) an initial exchange gain or loss (“the actual gain or loss”) accrues to the company for the current period,\nTable A or Table B below (as appropriate) shall apply and in any case falling within the first column of that Table, the actual gain or loss shall be deemed not to accrue but, subject to any conditions specified in the second column, the gain or loss specified in relation thereto in the third column shall be deemed to accrue and shall be an initial exchange gain or loss (as the case may be) accruing in the place of the actual gain or loss.\n(2) For the purposes of paragraph (1)(b) above, the question whether any initial exchange gain or loss has accrued shall be determined disregarding this Part and the regulation 2(2) provisions.\nTABLE A\nIf there is an attributed gain E\nCase for the current period\nCondition\nDeemed gain or loss\n1 Cumulative loss B and no cumulative taxed gain or loss\nB is greater than E\nLoss equal to B — E\n2 Cumulative loss B and a cumulative taxed loss C\ni B is not greater than E and C is greater than zero\ni Gain equal to C\nii B is greater than E and C is less than (B — E)\nii Loss equal to (B — E) — C\niii B is greater than E and C is greater than (B — E)\niii Gain equal to C — (B — E)\n3 Cumulative loss B and a cumulative taxed gain D\ni B is greater than E\ni Loss equal to (B — E) + D\nii B is not greater than E\nii Loss equal to D\n4 Cumulative gain A and a cumulative taxed gain D\ni A is greater than D\ni Gain equal to A — D\nii D is greater than A\nii Loss equal to D — A\n5 Cumulative gain A and a cumulative taxed loss C\nGain equal to C +plus; A\nTABLE B\nIf there is an attributed loss F\nCase for the current period\nCondition\nDeemed gain or loss\n1 Cumulative gain A and no cumulative taxed gain or loss\nA is greater than F\nGain equal to A — F\n2 Cumulative gain A and a cumulative taxed gain D\ni A is not greater than F\ni Loss equal to D\nii A is greater than F and D is less than (A — F)\nii Gain equal to (A — F) — D\niii A is greater than F and D is greater than (A — F)\niii Loss equal to D — (A — F)\n3 Cumulative gain A and a cumulative taxed loss C\ni A is greater than F\ni Gain equal to (A — F) + C\nii A is not greater than F and C is greater than zero\nii Gain equal to C\n4 Cumulative loss B and a cumulative taxed loss C\ni B is greater than C\ni Loss equal to B — C\nii C is greater than B\nii Gain equal to C — B\n5 Cumulative loss B and a cumulative taxed gain D\nLoss equal to B + D",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/uksi/1994/3226/regulation/12",
    "retrieved_at": "2026-10-29T13:20:08.181059+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."
}