Section 433 — Corporation Tax Act 2009: Transfer of loan relationship at notional carrying value

Transfer of loan relationship at notional carrying value 433 1 This section applies if in the course of the merger a transferor transfers an asset or liability representing a loan relationship to the transferee.

2 For the purpose of determining the credits and debits to be brought into account in respect of the loan relationship in accordance with this Part, the transferor and the transferee are treated as having entered into the transfer of that asset or liability for consideration of an amount equal to the notional carrying value of the asset or liability.

3 For the purposes of this section—

a . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . b “ notional carrying value ”, in relation to an asset or liability, means the amount which would have been its tax-adjusted carrying value based on the accounts of the transferor if a period of account had ended immediately before the date when the transferor ceased to be a party to the loan relationship.

4 This section is subject to section 434.