Corporation Tax Act 2009 section 335

Introduction to Chapter

Section 335 introduces the chapter on continuity of treatment for loan relationships when they are transferred within company groups, transferred as part of insurance business transfers, or involved in certain cross-border reorganisations.

• The chapter applies to three scenarios: intra-group loan transfers, insurance business loan transfers, and new securities issued on cross-border reorganisations
• Specific rules determine how taxable credits and deductible debits are calculated for each scenario, including where fair value accounting is used
• Additional provisions address what happens when a company that received a loan relationship through a group transfer subsequently leaves the group
• Anti-avoidance rules can disapply the entire chapter where the transferor is party to an avoidance arrangement involving a subsequent transfer by the transferee