Section 676AG — Corporation Tax Act 2010: Restriction on debits to be brought into account

Restriction on debits to be brought into account 676AG 1 This section has effect for the purpose of restricting the debits to be brought into account for the purposes of Part 5 of CTA 2009 (loan relationships) in respect of the transferred company's loan relationships.

2 The debits to be brought into account for the purposes of Part 5 of CTA 2009 for—

a the accounting period beginning immediately after the change in ownership, or b any subsequent accounting period, do not include relevant non-trading debits so far as amount A exceeds amount B.

3 Amount A is the sum of—

a the amount of those relevant non-trading debits, and b the amount of any relevant non-trading debits which have been brought into account for the purposes of that Part for any previous accounting period ending after the change in ownership.

4 Amount B is the amount of the taxable total profits of the accounting period ending with the change in ownership.

5 For the meaning of “relevant non-trading debit”, see section 730.