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SCHEDULES

SCHEDULE 5U.K.Group mismatch schemes

Repeal of sections 418 to 419 of CTA 2009U.K.

7(1)Omit sections 418 to 419 of CTA 2009 (loan relationships treated differently by connected debtor and creditor).U.K.

(2)In consequence of the repeals made by sub-paragraph (1), omit—

(a)in section 748ZA of ICTA (as inserted by paragraph 5 of Schedule 12 to this Act), subsection (5)(a),

(b)in Schedule 30 to FA 2009, paragraph 4,

(c)in section 416 of CTA 2009, subsection (4),

(d)in Schedule 1 to CTA 2010, paragraph 615, and

(e)section 29 of this Act.

(3)The repeals made by this paragraph have effect in relation to loan relationships to which a company is a party (or to which it is treated as a party under section 418(6A) of CTA 2009) on or after the commencement date.

(4)But amounts are to continue to be brought into account for the purposes of Part 5 of CTA 2009 disregarding the repeals made by sub-paragraph (1) if the amounts relate to a time before the commencement date; and the repeals made by sub-paragraph (2) have effect accordingly.