SCHEDULES
SCHEDULE 15 Loan relationships: savings and transitional provisions
Part I Corporation tax
Notional closing values of relevant assets
12
1
Subject to sub-paragraph (2) below, the notional closing value as at 31st March 1996 of any relevant asset representing a loan relationship of a company, or of any relevant liability, shall be taken for the purposes of paragraphs 5 and 11 above, to be an amount equal to the following amount, that is to say—
a
in the case of a chargeable asset, its market value on that date;
b
in the case of a relevant qualifying asset or relevant liability, the value given to it as at the company’s commencement day for the purpose of computing any attributed amount.
2
Sub-paragraph (3) below applies where a company, by notice in writing given on or before 30th September 1996 to an officer of the Board, F1made an election for the purposes of that sub-paragraph in relation to all of its relevant qualifying assets which—
a
apart from the election, would be given a notional closing value as at 31st March 1996 by sub-paragraph (1) above; and
b
but for Chapter II of Part II of the M1Finance Act 1993 (exchange gains and losses), would be chargeable assets.
3
Where such an election F2was made as respects those assets—
a
sub-paragraph (1) above shall not apply as respects those assets; but
b
the value of each of those assets as at 1st April 1996 shall be taken for the purposes of this Chapter F3and Part 5 of the Corporation Tax Act 2009 to be its market value on that date.
4
In this paragraph “chargeable asset” and “relevant asset” have the same meanings as in paragraph 11 above; and expressions used in this paragraph and paragraph 5 above have the same meanings in this paragraph as in that paragraph.