8(1)This paragraph applies where an approved scheme provides for the transfer of all the property, rights and liabilities to which a subsidiary of the relevant board is entitled or subject on the vesting day under the scheme.U.K.
(2)Where there is one relevant successor in relation to the subsidiary, any unallowed capital losses of the subsidiary shall be treated as allowable capital losses accruing to the relevant successor on the disposal of an asset on the vesting day under the scheme.
(3)Where there is more than one relevant successor in relation to the subsidiary, any unallowed capital losses of the subsidiary shall—
(a)be apportioned between the relevant successors in accordance with the scheme, and
(b)in the case of each relevant successor to which such losses are so apportioned, be treated as allowable capital losses accruing to it on the disposal of an asset on the vesting day under the scheme.
(4)In this paragraph—
“allowable capital losses” means losses which are allowable losses for the purposes of corporation tax on chargeable gains;
“relevant board” means the milk marketing board to which the scheme relates; and
“unallowed capital losses” means any allowable capital losses which have accrued to the subsidiary before the vesting day under the scheme, in so far as they have not been allowed as deductions from chargeable gains.