SCHEDULES
C1SCHEDULE 5Non-UK resident companies carrying on UK property businesses etc
Annotations:
Modifications etc. (not altering text)
PART 3Commencement and transitional provisions
Transitional provisions
I139
1
This paragraph applies if—
a
on or after the commencement date a loss arises in connection with a loan relationship of a company,
b
the loss is wholly or partly referable to a time before the commencement date (“the pre-commencement time”), and
c
had the loss arisen at the pre-commencement time it would have been brought into account in accordance with Part 3 of ITTOIA 2005 in calculating the profits of the UK property business of the company.
2
Section 327 (disallowance of imported losses etc) does not apply in relation to so much of the loss as is referable to the pre-commencement time.
Sch. 5 modified (22.7.2020) by Finance Act 2020 (c. 14), Sch. 6 para. 10