Section 404 | Restriction on deductions etc relating to FOTRA securities

(1)A company which meets conditions A and B is not to bring into account for the purposes of this Part—

(a)any amount relating to changes in the value of a FOTRA security, or

(b)any debit in respect of the loan relationship represented by the security, including any expenses related to holding the security or any transaction concerning it.

(2)Condition A is that the company is the beneficial owner of the security.

(3)Condition B is that the company is a company which would be exempt from corporation tax on the security under section 1279 (exemption of profits from FOTRA securities).

(4)In this section “FOTRA security” has the same meaning as in that section (see section 1280(1)).