Corporation Tax Act 2009

444 (1) Amend Schedule 15 (loan relationships: savings and transitional provisions) as follows. U.K.

(2) Omit—

(a) paragraph 2 (loan relationships terminated before 1st April 1996),

(b) paragraph 3 (basic rules for transitional accounting periods),

(c) paragraph 3A (adjustment of opening value where new accounting basis adopted as from an accounting period beginning on 1st April 1996), and

(d) paragraph 4 (application of accruals basis to pre-commencement relationships).

(3) In paragraph 5—

(a) in sub-paragraph (5) for “this Chapter is” substitute “ this Chapter (as it had effect immediately before 1st April 2009) was ”,

(b) in sub-paragraph (6)(b)—

(i) for “which is” substitute “ which was ”, and

(ii) after “this Chapter” insert “ (as it had effect immediately before 1st April 2009) ”, and

(c) in sub-paragraph (7)—

(i) for “taken to be” substitute “ taken to have been ”,

(ii) for “is treated” substitute “ was treated ”, and

(iii) after “paragraph 4 above” insert “ (as it had effect immediately before 1st April 2009) ”.

(4) In paragraph 6—

(a) in sub-paragraph (3) for “this Chapter” substitute “ Part 5 of the Corporation Tax Act 2009 ”,

(b) for sub-paragraphs (4) to (7) substitute—

“(4) Sub-paragraphs (1) to (3) above do not apply if the company duly made an election for the purposes of this sub-paragraph as it had effect on 30th September 1996.”, and

(c) in sub-paragraph (8)—

(i) for “section 82(2) of this Act” substitute “ section 297 of the Corporation Tax Act 2009 ”, and

(ii) at the end insert “ under Part 5 of that Act ”.

(5) In paragraph 9—

(a) in sub-paragraph (1) after “this Chapter” insert “ or Part 5 of the Corporation Tax Act 2009 ”, and

(b) in sub-paragraph (2)—

(i) after “this Chapter”, in the first place where it occurs, insert “ or that Part ”, and

(ii) after “this Chapter”, in the second place where it occurs, insert “ or, as the case may be, that Part ”.

(6) Omit paragraph 10 (adjustments of opening value for mark to market accounting in the case of chargeable assets).

(7) In paragraph 11 (other adjustments in the case of chargeable assets etc)—

(a) in sub-paragraphs (1) and (3)(a) for “this Chapter” substitute “ Part 5 of the Corporation Tax Act 2009 ”,

(b) in sub-paragraph (6) at the end insert “ under Part 5 of the Corporation Tax Act 2009 ”, and

(c) in sub-paragraph (8) after “this Chapter” insert “ and Part 5 of the Corporation Tax Act 2009 ”.

(8) In paragraph 11A(2) (reduction of paragraph 11 credit where section 251(4) of 1992 Act prevents paragraph 8 loss) for “this Chapter” substitute “ Part 5 of the Corporation Tax Act 2009 ”.

(9) In paragraph 12 (notional closing values of relevant assets)—

(a) in sub-paragraph (2) for “makes” substitute “ made ”, and

(b) in sub-paragraph (3)—

(i) for “is made” substitute “ was made ”, and

(ii) after “this Chapter” insert “ and Part 5 of the Corporation Tax Act 2009 ”.

(10) Omit—

(a) paragraph 13 (further transitional rules where interest under loan relationships),

(b) paragraph 14 (transitional in respect of incidental expenses already allowed), and

(c) paragraph 15 (holdings of unit trusts etc).

(11) In paragraph 16 (bad debt relieved before commencement of FA 1996)—

(a) in sub-paragraph (2)—

(i) after “this Chapter”, in the first place where it occurs, insert “ or Part 5 of the Corporation Tax Act 2009 ”, and

(ii) after “this Chapter”, in the second place where it occurs, insert “ or that Part ”,

(b) in sub-paragraph (3)—

(i) after “this Chapter”, in the first place where it occurs, insert “ and Part 5 of the Corporation Tax Act 2009 ”, and

(ii) after “this Chapter”, in the second place where it occurs, insert “ and that Part ”, and

(c) in sub-paragraph (4) for “falls” substitute “ fell ”.

(12) In paragraph 17 (transitional for overseas sovereign debt etc)—

(a) in sub-paragraph (1) after “this Chapter” insert “ and Part 5 of the Corporation Tax Act 2009 ”, and

(b) in sub-paragraph (3)—

(i) after “this Chapter”, in the first place where it occurs, insert “ and Part 5 of the Corporation Tax Act 2009 ”, and

(ii) after “this Chapter”, in the second place where it occurs, insert “ and that Part ”.

(13) Omit paragraph 18 (transitional for accrued income scheme).

(14) In paragraph 19 (deep discount securities)—

(a) omit sub-paragraphs (1) and (2),

(b) in sub-paragraphs (3A), (4), (5), (6), (7) and (8) for “this Chapter” substitute “ Part 5 of the Corporation Tax Act 2009 ”,

(c) omit sub-paragraph (10), and

(d) in sub-paragraph (11)(b) for “this Chapter is” substitute “ this Chapter was ”.

(15) In paragraph 20 (deep gain securities)—

(a) omit sub-paragraph (1),

(b) in sub-paragraphs (2A) and (3) for “this Chapter” substitute “ Part 5 of the Corporation Tax Act 2009 ”, and

(c) in sub-paragraph (5) for “this Chapter is” substitute “ this Chapter (as it had effect immediately before 1st April 2009) was ”.

(16) In paragraph 21 (convertible securities)—

(a) omit sub-paragraph (1), and

(b) in sub-paragraphs (2) and (4) for “this Chapter” substitute “ Part 5 of the Corporation Tax Act 2009 ”.