Loss to be relieved against other participators’ profitsU.K.
7(1)The intermediate unrelieved loss shall (but only for the purposes of determinations under this Schedule) be relieved against relevant profits accruing to a different owner.
(2)The provisions of paragraphs 8 to 10 apply for the purposes of relieving the intermediate unrelieved loss under this paragraph.
(3)In this paragraph and paragraph 8, a “different owner” means any participator in the field who—
(a)has the loss-maker’s interest at any time (whether before or after the transfer) when the loss-maker does not have that interest, or
(b)has a part of the loss-maker’s interest at any time (whether before or after the transfer) when the loss-maker does not have that part.
(4)In sub-paragraph (3) “the loss-maker’s interest” means—
(a)if the loss-maker is the old participator or the new participator, the transferred interest;
(b)if the loss-maker is a subsequent new owner and at any time (whether before or after the transfer) has the whole of the transferred interest, that interest; and
(c)if the loss-maker is a subsequent new owner and paragraph (b) does not apply, the aggregate of each part of the transferred interest that at any time (whether before or after the transfer) is a part that the loss-maker has.