Section 676AG | Restriction on debits to be brought into account

(1)This section has effect for the purpose of restricting the debits to be brought into account for the purposes of Part 5 of CTA 2009 (loan relationships) in respect of the transferred company's loan relationships.

(2)The debits to be brought into account for the purposes of Part 5 of CTA 2009 for—

(a)the accounting period beginning immediately after the change in ownership, or

(b)any subsequent accounting period,

do not include relevant non-trading debits so far as amount A exceeds amount B.

(3)Amount A is the sum of—

(a)the amount of those relevant non-trading debits, and

(b)the amount of any relevant non-trading debits which have been brought into account for the purposes of that Part for any previous accounting period ending after the change in ownership.

(4)Amount B is the amount of the taxable total profits of the accounting period ending with the change in ownership.

(5)For the meaning of “relevant non-trading debit”, see section 730.