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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.U.K.
(2)[Part 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.
(3)Expressions used in this paragraph and in [Part 5 of the Corporation Tax Act 2009] have the same meanings in this paragraph as in [that Part].
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