SCHEDULES

SCHEDULE 9Taxation provisions relating to nuclear transfer schemes

Part 2Transfers relating to BNFL or the UKAEAetc.

Continuity in relation to loan relationships

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1

This paragraph applies if, in consequence of a transfer to which this Part of this Schedule applies, the transferee 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 transferee 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 transferee 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 F2Part 5 of the Corporation Tax Act 2009 have the same meanings in this paragraph as in F2that Part.