Corp Tax Computation-FRS102-Ord Listed Shs held

[taxwize]

A singleton company holds a portfolio of ordinary shares and may want to adopt FRS102-The company does not trade shares for any clientele. Provided these shares are deemed to be Basic Financial Instruments is it safe to say that any movements in P&L to arrive at fair value (necessary because they are listed), will be ignored for the relevant CT tax computation?(I appreciate these holdings will be requiring a deferred tax report)In other words, any P&L adjustments will be added back or deducted in the tax comp - thus the enduring principle remains of taxation of share gains and losses once and once only, at point of disposal.

GOV.UK "FRS102 Overview paper" states on Financial Instruments-
"Tax treatment
For companies most financial instruments will fall to be loan relationships (under Part 5 CTA 2009), non-lending money debts (treated as loan relationships under chapter 2 of Part 6 CTA 2009) or derivative contracts (under Part 7 CTA 2009). UK tax law provides in general that the accounting treatment of these types of instruments is followed for tax purposes. This paper does not cover those financial instruments that fall outside of these categories - for example, equity instruments in the form of shares and guarantees."

As the above specifically ignores equity instruments such as ordinary shares I guess I am trying to prove a negative as we often have to! If my assumptions are incorrect this company would have a massive dry tax charge if adopting FRS102 because up to now it has been prepared on basis of historic cost so there would be a hefty movement to fair value.

Or can we instead look at this by saying an ordinary share is not a loan relationship so a succinct conclusion that as such these ordinary shares are ignored for CT?

Comments gratefully received-thank you