23 Loan relationships: debts becoming held by connected company

23  Loan relationships: debts becoming held by connected company

(1)     Chapter 6 of Part 5 of CTA 2009 (loan relationships: connected companies and impairment losses and releases of debt) is amended as follows.

(2)     In section 362 (parties becoming connected where creditor's rights subject to impairment adjustment)—

(a)     in subsection (1)—

(i)     omit paragraph (c) (impairment in pre-connection carrying value of creditor's loan relationship), and

(ii)     omit the “and” before that paragraph and, at the end of paragraph (a), insert “and”,

(b)     for subsections (3) and (4) substitute—

“(3)     The amount treated as released is the amount (if any) by which the pre-connection carrying value in D's accounts exceeds the pre-connection carrying value in C's accounts.

(4)     In subsection (3)—

“the pre-connection carrying value in D's accounts” means the amount that would be the carrying value of the liability representing the loan relationship in D's accounts if a period of account had ended immediately before C and D became connected, and

“the pre-connection carrying value in C's accounts” means—

(a)     in any case where C was a party to the loan relationship as creditor on the last day of the period of account ending immediately before

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