After section 807F insert—

“807GTax treated as chargeable in respect of relevant transactions

(1)

This Part, including any arrangements having effect by virtue of section 788, is to apply as if the tax that would have been chargeable as mentioned in section 807F(1) had been chargeable.

(2)

In calculating tax notionally chargeable under subsection (1), it is assumed—

(a)

that to the extent permitted by the law of the other member State mentioned in section 807F(1) losses arising on the relevant transfer are set against profits arising on it, and

(b)

that any relief available under that law is claimed.

(3)

In this section “the relevant transfer” means—

(a)

the transfer of assets or liabilities mentioned in paragraph (a) or (b) of section 807F(5),

(b)

the transfer of rights and liabilities mentioned in paragraph (c) or (d) of that section, or

(c)

the transfer of intangible fixed assets mentioned in paragraph (e) or (f) of that section.”