Section 404 — Corporation Tax Act 2009: Restriction on deductions etc relating to FOTRA securities

Restriction on deductions etc relating to FOTRA securities 404 1 A company which meets conditions A and B is not to bring into account for the purposes of this Part—

a any amount relating to changes in the value of a FOTRA security, or b any debit in respect of the loan relationship represented by the security, including any expenses related to holding the security or any transaction concerning it.

2 Condition A is that the company is the beneficial owner of the security.

3 Condition B is that the company is a company which would be exempt from corporation tax on the security under section 1279 (exemption of profits from FOTRA securities).

4 In this section “ FOTRA security ” has the same meaning as in that section (see section 1280(1)).