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SCHEDULES

SCHEDULE 10E+W+STaxation provisions relating to transfer schemes

Part 2 E+W+SOther transfers under section 1(2) schemes

Continuity in relation to loan relationshipsE+W+S

18(1)For the purposes of the application of [F1Part 5 of the Corporation Tax Act 2009] (loan relationships) in relation to a relevant transfer, the transferee and the transferor are to be treated as if, at the time of the transfer, they were members of the same group.E+W+S

(2)In sub-paragraph (1), the reference to being members of the same group must be construed in accordance with [F2section 335(6) of] that Act.

Textual Amendments

F1Words in Sch. 10 para. 18(1) substituted (with effect in accordance with s. 1329(1) of the amending Act) by Corporation Tax Act 2009 (c. 4), s. 1329(1), Sch. 1 para. 667(5)(a) (with Sch. 2 Pts. 1, 2)

F2Words in Sch. 10 para. 18(2) substituted (with effect in accordance with s. 1329(1) of the amending Act) by Corporation Tax Act 2009 (c. 4), s. 1329(1), Sch. 1 para. 667(5)(b) (with Sch. 2 Pts. 1, 2)

Commencement Information

I1Sch. 10 para. 18 in force at 8.6.2005 by S.I. 2005/1444, art. 2(1), Sch. 1