428(1)  This section applies if–

(a)there is a qualifying change of ownership in relation to a company on any day (“the relevant day”),

(b)on the following day the company is treated under section 425 as incurring an expense of a business and an accounting period of the company (“period 1”) begins,

(c)the company makes a loss in period 1 or a later accounting period,

(d)apart from this section some or all of that loss (“the carried forward loss”) would be carried forward to the next accounting period of the company after the accounting period in which the loss is made (“the subsequent period”),

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