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FORTHCOMING CHANGE relating to the treatment of forex under UK transfer pricing rules: From 1 January 2026, the Finance Bill 2026 introduces a series of updates to the UK transfer pricing framework. Among the measures are changes that bring foreign exchange gains and losses arising on loan relationships and derivative contracts within the main transfer pricing rules, while leaving the tax rules for forex hedging untouched. Previously, such amounts were adjusted under bespoke provisions in the loan relationships and derivatives regimes addressing non‑arm’s length transactions. The changes also broaden the existing loan relationships anti‑avoidance rule in CTA 2009, s 452, to accommodate a new election allowing companies to be treated as guarantors of a non‑arm’s length borrowing for transfer pricing purposes. For further detail, refer to News Analysis: Budget 2025—Tax analysis—International and Tax—publication of Finance Bill 2026. Numerous entries in a company’s corporation tax return will be tax‑adjusted figures sourced from accounts prepared in line with generally accepted accounting practice (GAAP)—either UK GAAP or international accounting standards (IAS). In...
A company is required to observe the statutory requirements in the Companies Act 2006 (CA 2006) concerning the maintenance of accounting records. Further, additional rules on accounting records may govern a listed company, an AIM company, or a company whose securities are admitted to the AQSE Main Market, AQSE Trading or the AQSE Growth Market (previously the NEX Exchange Main Board, NEX Exchange Secondary Market and NEX Exchange Growth Market); however, these fall beyond the remit of this Practice Note. Certain or all of the statutory provisions on accounting records might likewise extend to other companies and entities, but that question also lies outside the remit of this Practice Note. This Practice Note does not consider those additional regimes, or the potential application of the statutory provisions to other bodies. The duty to keep accounting records All companies must retain adequate accounting records. Their role is to ensure transactions are captured so that the company can present its financial position and prepare accounts that comply with CA 2006...
Prepared by Peter Westaway of Deloitte LLP and reviewed by Martin Hooper of Barnett Waddingham. THIS PRACTICE NOTE APPLIES IN RELATION TO DEFINED BENEFIT SCHEMES. Accounting for pensions is often intricate, particularly within groups where multiple entities take part in a single arrangement or scheme. The aim of this Practice Note is to outline, at a high level, how pensions are accounted for by UK employers and by schemes. Company reporting frameworks In the UK, corporate reports follow one of the following frameworks: International Financial Reporting Standards (IFRS), under which International Accounting Standard 19 (IAS 19) governs employers’ accounting for defined benefit pensions FRS 101—the Reduced Disclosure Framework (reflecting IFRS recognition and measurement while imposing reduced disclosure requirements) FRS 102—the Financial Reporting Standard applicable in the UK and Republic of Ireland, where Section 28 governs the accounting for defined benefit pensions FRS 105—the Financial Reporting Standard applicable to the Micro-entities Regime, where Section 23 governs the accounting for defined benefit pensions ...