Taxation (International and Other Provisions) Act 2010 section 117

Tax treated as chargeable in respect of transfer of loan relationship, derivative contract or intangible fixed assets

Section 117 ensures that, for double taxation relief purposes, foreign tax that would have been charged on the transfer of loan relationships, derivative contracts or intangible fixed assets — but was not charged because of the EU Mergers Directive — is still treated as if it had been charged.