Paragraph 17 I1

Section 334 (non-UK resident company ceasing to hold loan relationship for UK permanent establishment) is amended as follows.

In the heading, for “UK permanent establishment” substitute “ section 333(2) purposes ”.

In subsection (1) for the words from “the purposes” to “United Kingdom” substitute “ section 333(2) purposes ”.

In subsection (3)(b) for “the purposes of the permanent establishment” substitute “ section 333(2) purposes ”.

After subsection (4) insert—

“(5)

An asset or liability ceases to be held or owed for section 333(2) purposes if and in so far as—

(a)

it ceases to be held or owed for any purposes mentioned in section 333(2), and

(b)

on doing so, it does not begin or continue to be held or owed for any of the other purposes so mentioned.”