Corporation Tax Act 2009 section 54

Opening and closing values determined under Schedule 15 to the Finance Act 1996

Section 54 preserves the validity of opening and closing values for loan relationships that were determined under the transitional rules in Schedule 15 to the Finance Act 1996, despite those rules being repealed by the Corporation Tax Act 2009.

• Schedule 15 to the Finance Act 1996 contained savings and transitional provisions for the tax treatment of loan relationships.
• Any opening or closing value that was to be determined by reference to Schedule 15 immediately before the Corporation Tax Act 2009 came into force remains valid.
• The repeal of Schedule 15 provisions (or provisions affecting Schedule 15) by the Corporation Tax Act 2009 does not alter how those values were determined.
• This ensures that historical valuations already established under the old rules are not retrospectively disturbed by the new legislation.