Section 477A(3) (where regulations apply for any year of assessment, dividends or interest to be dealt with for the purposes of corporation tax as there described) is amended as follows.

In paragraph (a) (liability to pay to be treated as a liability arising under a loan relationship) at the beginning insert “ to the extent that it would not otherwise fall to be so regarded, ”.

In paragraph (aa) (dividends or interest payable to company to be treated as payable in pursuance of right under loan relationship) after “payable to a company,” insert “ then, to the extent that they would not otherwise fall to be so regarded, ”.