SCHEDULES

SCHEDULE 10Taxation provisions relating to transfer schemes

Part 2Other transfers under section 1(2) schemes

Continuity in relation to loan relationships

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(1)

For the purposes of the application of F1Part 5 of the Corporation Tax Act 2009 (loan relationships) in relation to a relevant transfer, the transferee and the transferor are to be treated as if, at the time of the transfer, they were members of the same group.

(2)

In sub-paragraph (1), the reference to being members of the same group must be construed in accordance with F2section 335(6) of that Act.