Part 5Loan Relationships

Chapter 4Continuity of treatment on transfers within groups or on reorganisations

Transferee leaving group after replacing transferor as party to loan relationship

345Transferee leaving group otherwise than because of exempt distribution

(1)

This section applies if—

(a)

the transferee ceases to be a member of the relevant group, and

(b)

it does not so cease just because of a distribution which is exempt F1as a result of section 1075 of CTA 2010 (exempt distributions).

(2)

F2... This Part applies as if—

(a)

the transferee had assigned the asset or liability representing the relevant loan relationship immediately before ceasing to be a member of the relevant group,

(b)

the assignment had been for consideration of an amount equal to the fair value of the asset or liability at that time, and

(c)

the transferee had immediately reacquired the asset or liability for consideration of the same amount.

F3(3)

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F3(4)

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F3(5)

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