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
I111
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.