SCHEDULES
SCHEDULE 26 Transfers: tax
Part III Transfers from BR to SRA
Loan relationships
17
1
Sub-paragraph (2) applies if, as a result of a relevant transfer, the transferee replaces the transferor as a party to a loan relationship.
2
F1Part 5 of the Corporation Tax Act 2009 is to have effect in relation to the time when the relevant transfer takes effect and any later time as if—
a
the transferee had been a party to the loan relationship at the time the transferor became a party to the loan relationship and at all times since that time, and
b
the loan relationship to which the transferee is a party after the time the transfer takes effect is the same loan relationship as that to which, by virtue of paragraph (a), it is treated as having been a party before that time.