257Transfer involving person within the charge to income taxU.K.
(1)This section explains how section 255 works if—
(a)the transferor is a company within the charge to corporation tax and the transferee is a person within the charge to income tax, or
(b)the transferor is a person within the charge to income tax and the transferee is a company within the charge to corporation tax.
(2)Section 255 applies only for the purpose of determining—
(a)whether the company within the charge to corporation tax is entitled to a deduction (or part of a deduction) under section 254, and
(b)the amount of any such deduction.
(3)Accordingly, any reference to—
(a)whether a person is entitled to a deduction (or part of a deduction) under section 254, or
(b)the amount of any such deduction,
is ignored if the person is within the charge to income tax.
(4)For any entitlement of a person within the charge to income tax to a deduction for any of the expenditure, see sections 316 to 318 of ITTOIA 2005 (corresponding income tax provisions).