SCHEDULES

SCHEDULE 4Transitional provision relating to Part 2

Tax consequences of transfers by virtue of paragraph 1(3)

2

(1)

For the purposes of the application of Part 5 of the Corporation Tax Act 2009 (loan relationships) in relation to a transfer by virtue of paragraph 1(3), the Comptroller and Auditor General and NAO are to be treated as if, at the time of the transfer, they were members of the same group.

(2)

In sub-paragraph (1) the reference to being members of the same group is to be read in accordance with section 335(6) of that Act.