SCHEDULE 24Transfers and transfer schemes: tax provisions

PART 1Transfer under paragraph 63 of Schedule 16

1(1)For the purposes of any enactment about income tax or corporation tax, the Office and the HCA are to be treated as the same person.

(2)In particular, the transfer effected by paragraph 63 of Schedule 16 is to be disregarded for those purposes.

(3)Accordingly, that transfer is not to be regarded for the purposes of Part 8 of the Corporation Tax Act 2009 (gains and losses from intangible fixed assets) as involving any realisation of an asset by the Office or acquisition of an asset by the HCA.

(4)In this paragraph—