SCHEDULES
SCHEDULE 9Taxation provisions relating to nuclear transfer schemes
Part 1Transfers to the NDA or a subsidiary of the NDA
Continuity in relation to loan relationships
11
(1)
This paragraph applies if, in consequence of a section 39 scheme, the NDA or a subsidiary of the NDA replaces a person 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 transfer takes effect and any later time as if—
(a)
the NDA or its subsidiary had been a party to the loan relationship at the time when the transferor became a party to it and at all times since that time; and
(b)
the loan relationship to which the NDA or its subsidiary is a party after the time when 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.