Section 346 — Corporation Tax Act 2009: Transferee leaving group because of exempt distribution

Transferee leaving group because of exempt distribution 346 1 This section applies if—

a the transferee ceases to be a member of the relevant group just because of a distribution which is exempt as a result of section 1075 of CTA 2010 (exempt distributions),

and b there is a chargeable payment within the meaning of section 1088(1) of CTA 2010 (chargeable payments connected with exempt distributions) within 5 years after the making of that distribution. 2 ... This Part applies as if—

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