SCHEDULES

F1 SCHEDULE 7A Restriction on set-off of pre-entry losses

Companies changing groups on certain transfers of shares etc.

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For the purposes of this Schedule, and without prejudice to paragraph 11 above, where—

(a)

a company which is a member of a group of companies becomes at any time a member of another group of companies as the result of a disposal of shares in or other securities of that company or any other company; and

(b)

that disposal is one on which, by virtue of any F2of the no gain/no loss provisions, neither a gain nor a loss would accrue,

this Schedule shall have effect in relation to the losses that accrued to that company before that time and the assets held by that company at that time as if any time when it was a member of the first group were included in the period during which it is treated as having been a member of the second group.