SCHEDULES

SCHEDULE 10Taxation provisions relating to transfer schemes

Part 3Transfers under section 12 schemes

Loan relationships

I128

1

F1Section 444 of the Corporation Tax Act 2009 is not to have effect where, as a result of a relevant transfer, the transferee replaces the transferor as a party to a loan relationship.

2

Expressions used in this paragraph and in F2Part 5 of the Corporation Tax Act 2009 have the same meanings in this paragraph as in F2that Part.