SCHEDULE 5Tax treatment of financing costs and income
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“348AFinancial statements: business combinations to which the worldwide group is a party
(1)
Subsection (2) applies where—
(a)
a business combination or demerger occurs to which the worldwide group is party (“the relevant event”),
(b)
as a result of the relevant event, there is a change in the identity of the ultimate parent of—
(i)
the worldwide group, or
(ii)
any other group which is party to the relevant event, and
(c)
financial statements of the worldwide group are drawn up, or (in the absence of this section) would be treated as drawn up under section 348, for a period which begins before and ends after the relevant event (“the straddling period”).
(2)
This Part (apart from this section) applies as if—
(a)
no financial statements of the worldwide group had been drawn up for the straddling period,
(b)
section 348 did not apply to that period, and
(c)
IAS financial statements had been drawn up in respect of each of the following—
(i)
the period beginning at the same time as the straddling period and ending immediately before the relevant event, and
(ii)
the period beginning with the relevant event and ending at the same time as the straddling period.
(3)
For the purposes of this section—
(a)
“demerger” means a transaction by which one or more groups cease to be members of a group,
(b)
a group is party to a business combination or demerger if the business combination or demerger affects one or more members of the group, and
(c)
the reference to “IAS financial statements” is to be construed in accordance with section 348(5).”