After paragraph 10 (imported losses etc) insert—

“Deemed assignment of assets and liabilities on company ceasing to be resident in UK etc

10A

(1)

This paragraph applies if at any time (“the relevant time”)—

(a)

a company ceases to be resident in the United Kingdom, or

(b)

in the case of a company that is not resident in the United Kingdom, an asset or liability representing a loan relationship of the company ceases to be held for the purposes of a permanent establishment of the company in the United Kingdom in any circumstances not involving a related transaction.

(2)

In a case falling within sub-paragraph (1)(a) above, this Chapter shall have effect as if the company had—

(a)

immediately before the relevant time, assigned the assets and liabilities that represent its loan relationships for a consideration of an amount equal to their fair value at that time, and

(b)

immediately reacquired them for a consideration of the same amount.

(3)

Sub-paragraph (2) above does not apply in relation to an asset or a liability to the extent that, immediately after the relevant time, it is held or owed for the purposes of a permanent establishment of the company in the United Kingdom.

(4)

In a case falling within sub-paragraph (1)(b) above, this Chapter shall have effect as if the company had—

(a)

immediately before the relevant time, assigned the asset or liability, so far as ceasing to be held or owed for the purposes of the permanent establishment, for a consideration of an amount equal to its fair value at that time, and

(b)

immediately reacquired it for a consideration of the same amount.

(5)

In this paragraph “fair value” shall be construed in accordance with section 85 of this Act.”.