½Û×ÓÊÓƵ

Special rules apply where:

1. Ìý

   •ÌýÌýÌýÌý a company (A) which is a party to a loan relationship is replaced directly or indirectly by another company (B), where the two companies are members of the same group and are within the charge to corporation tax¹ (for this purpose a group is a parent company and its 75% subsidiaries²)

2. Ìý

   •ÌýÌýÌýÌý a replacement occurs as a result of a series of transactions which have the same effect as a related transaction between A and B where each of A and B was a member of the same group at any time in the course of the series of transactions³ (this could be a back-to-back arrangement or a novation of a debt) or

3. Ìý

   •ÌýÌýÌýÌý B becomes a party to a loan relationship under which⁴:

4. 1. Ìý

      –ÌýÌýÌýÌý its rights are equivalent to those of a loan relationship to which A has ceased to be a party or

   2. Ìý

      –ÌýÌýÌýÌý its obligations are equivalent to those of a loan relationship to