Managing tax on Forex

Sterling has had a bit of a turbulent time ever since the Brexit referendum and this foreign exchange (“forex”) volatility, with sharp falls and rises is not likely to end until there is some certainty over our future trading arrangements...

Exchange losses arising on change in functional currency allowed by UT

The Upper Tier Tax Tribunal (UTT) has dismissed HMRC’s appeal against the First Tier Tribunal’s (FTT) decision to allow exchange losses appearing in the accounts and arising on a change in functional currency of various companies in the Smith &...

Whether UK GAP permitted a change of functional currency

A UK subsidiary (BUKH) of a US group (Ball group) changed its functional currency for UK accounting purposes from UK£ to US$, resulting in a purported foreign exchange tax loss of £43m without a similar economic loss.  BUKH contended it...