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Legislation
Corporation Tax Act 2009

Crossheading Transferee leaving group after replacing transferor as party to loan relationship

  • Section 344 Introduction
  • Section 345 Transferee leaving group otherwise than because of exempt distribution
  • Section 346 Transferee leaving group because of exempt distribution
  1. Transferee leaving group after replacing transferor as party to loan relationship
  2. Transferee leaving group because of exempt distribution

Section 346 | Transferee leaving group because of exempt distribution

From legislation.gov.uk

(1)This section applies if—

(a)the transferee ceases to be a member of the relevant group just because of a distribution which is exempt as a result of section 1075 of CTA 2010 (exempt distributions), and

(b)there is a chargeable payment within the meaning of section 1088(1) of CTA 2010 (chargeable payments connected with exempt distributions) within 5 years after the making of that distribution.

(2)... This Part applies as if—

(a)the transferee had assigned the asset or liability representing the relevant loan relationship immediately before the chargeable payment was made,

(b)the assignment had been for consideration of an amount equal to the fair value of the asset or liability immediately before the transferee ceased to be a member of the relevant group, and

(c)the transferee had immediately reacquired the asset or liability for consideration of the same amount.

(3)Repealed

(4)Repealed

(5)Repealed

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