Corporation Tax Act 2009 section 703

"Chargeable asset"

Section 703 defines what counts as a "chargeable asset" for the purposes of the derivative contracts rules in Part 7 of the Corporation Tax Act 2009.

• An asset is a chargeable asset if any gain on its disposal would be a chargeable gain subject to corporation tax.
• The definition of "asset" is broad enough to include obligations under futures contracts.
• Futures contract obligations are included because section 143 of the Taxation of Chargeable Gains Act 1992 treats them as assets whose disposal falls within the chargeable gains regime.
• A futures obligation becomes relevant where market price movements mean the obligation is heading towards a profit, and the obligation is disposed of before the contract reaches its delivery date.