Section 345 — Corporation Tax Act 2009: Transferee leaving group otherwise than because of exempt distribution

Transferee leaving group otherwise than because of exempt distribution 345 1 This section applies if—

a the transferee ceases to be a member of the relevant group, and b it does not so cease just because of a distribution which is exempt as a result of section 1075 of CTA 2010 (exempt distributions) . 2 ... This Part applies as if—

a the transferee had assigned the asset or liability representing the relevant loan relationship immediately before ceasing to be a member of the relevant group, b the assignment had been for consideration of an amount equal to the fair value of the asset or liability at that time, and c the transferee had immediately reacquired the asset or liability for consideration of the same amount. 3 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .