7(1)The amendments made by paragraphs 3 to 5 and 6(2) and (3) have effect in relation to any arrangements whenever made.U.K.
(2)But, in relation to arrangements made before 6th March 2007, amounts are as a result of any of those amendments—
(a)to be charged to tax, or
(b)to be brought into account in calculating any income for tax purposes or deducted from any income for tax purposes,
only if the amounts arise on or after that date.
(3)In any case where, in relation to arrangements made before that date, a person is treated as a result of any of those amendments as being a party to any loan relationship—
(a)a period of account is to be treated for the purposes of Chapter 2 of Part 4 of FA 1996 as beginning on that date, and
(b)the loan relationship is to be treated for those purposes as being entered into by the person for a consideration equal to the notional carrying value of the liability representing the relationship.
(4)For this purpose the notional carrying value is the amount that would have been the carrying value of the liability in the accounts of the person if a period of account had ended immediately before that date.
(5)“Carrying value” has the same meaning here as it has for the purposes of paragraph 19A of Schedule 19 to FA 1996.
(6)The amendment made by paragraph 6(4) comes into force on the day on which this Act is passed.