ABSTRACT
Such a swap should qualify for these purposes as a contract for differences
and be treated as a financial derivative instrument for the purposes of FRS 13
(FA 2002 Sch 26 paras 2(2)((c), 3(1)(a)).
A swap payment is not subject to withholding tax if the profits and losses of the
swap are computed in accordance with Sch 26 (Sch 26 para 51).
