327 Disallowance of imported losses etc
Corporation Tax Act 2009 (2009 c 4) | Legislation

327  Disallowance of imported losses etc

(1)     This section applies for an accounting period of a company (“the loss period”) if—

(a)     apart from this section, a loss arising in connection with a loan relationship of the company would fall to be brought into account for the purposes of this Part, and

(b)     the loss is wholly or partly referable to a time when the relationship was not subject to United Kingdom taxation.

(2)     The amounts brought into account

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