SCHEDULES

SCHEDULE 2Taxation provisions relating to re-structuring etc

5Transfers of property, rights and liabilities by transfer schemes

For the purposes of Chapter 4 of Part 5 of the Corporation Tax Act 2009 (loan relationships: continuity of treatment on transfers within groups or on reorganisations) the transferor and transferee are to be treated in relation to a relevant transfer as if, for the purposes of the transfer, they were members of the same group.