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.U.K.
(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.
(3)Expressions used in this paragraph and in [F2Part 5 of the Corporation Tax Act 2009] have the same meanings in this paragraph as in [F2that Part].
Textual Amendments
F1Words in Sch. 26 para. 17(2) substituted (with effect in accordance with s. 1329(1) of the amending Act) by Corporation Tax Act 2009 (c. 4), s. 1329(1), Sch. 1 para. 473(4)(a) (with Sch. 2 Pts. 1, 2)
F2Words in Sch. 26 para. 17(3) substituted (with effect in accordance with s. 1329(1) of the amending Act) by Corporation Tax Act 2009 (c. 4), s. 1329(1), Sch. 1 para. 473(4)(b) (with Sch. 2 Pts. 1, 2)