Corporation Tax Act 2009 Explanatory Notes

Section 362: Parties becoming connected where creditor’s rights subject to impairment adjustment

1153.Under this section where a debtor company and a creditor company become connected, any reduction in the value of the debt as a result of an impairment loss which was not yet reflected in the book value of the debt at the time of acquisition is treated as a release by the creditor. It is based on paragraph 4A(1), (4), (5), (7) and (10) of Schedule 9 to FA 1996.

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