There are special rules in CTA09/PT5/CH4 (CTA09/S335 to S347) where a company transfers a loan relationship to another company in the same group. The rule is similar to the CG treatment under TCGA92/S171 (see CG45300+) where assets may be transferred between group companies at no gain/no loss.

‘Group’ here takes its meaning from TCGA92/S170 (CG45100+), but excludes non-UK companies, by virtue of CTA09/S334(2), which applies the rules only to transactions between group members that are within the charge to corporation tax in respect of that transaction.

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