Corporation Tax Act 2009 (c. 4)

Part 6 U.K. Relationships treated as loan relationships etc

[F1 Chapter 6A U.K. Shares accounted for as liabilities

Textual Amendments

F1 Pt. 6 Ch. 6A inserted (retrospective and with effect in accordance with Sch. 24 paras. 12, 13-16 of the commencing Act) by Finance Act 2009 (c. 10), Sch. 24 para. 412

521F Shares becoming or ceasing to be shares to which section 521B applies U.K.

(1) This section applies if at any time section 521B begins or ceases to apply in the case of a share held by the investing company.

(2) The investing company is treated for the purposes of Part 5—

(a) as having disposed of the share immediately before that time for consideration of an amount equal to the notional carrying value of the share at that time, and

(b) as having immediately reacquired it for consideration of the same amount.

(3) In subsection (2) “ notional carrying value ”, in relation to the share, means the amount which would have been [F2 its tax-adjusted carrying value based on] the accounts of the investing company if a period of account had ended immediately before section 521B began or ceased to apply in the case of the share and the investing company.

F3 (4) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .]

Textual Amendments

F2 Words in s. 521F(3) substituted (with effect in accordance with Sch. 7 Pt. 6 of the amending Act) by Finance (No. 2) Act 2015 (c. 33), Sch. 7 para. 57(a)

F3 S. 521F(4) omitted (with effect in accordance with Sch. 7 Pt. 6 of the amending Act) by virtue of Finance (No. 2) Act 2015 (c. 33), Sch. 7 para. 57(b)

Modifications etc. (not altering text)

C1 S. 521F excluded (with effect in accordance with Sch. 24 paras. 13-16 of the commencing Act) by Finance Act 2009 (c. 10), Sch. 24 para. 15(4)