{
  "url": "https://openlegislation.uk/income-and-corporation-taxes-act-1988/schedule-28A/paragraph-9",
  "json_url": "https://openlegislation.uk/income-and-corporation-taxes-act-1988/schedule-28A/paragraph-9.json",
  "legislation": "ukpga/1988/1",
  "legislation_title": "Income and Corporation Taxes Act 1988",
  "legislation_url": "https://openlegislation.uk/income-and-corporation-taxes-act-1988",
  "path": "schedule/28A/paragraph/9",
  "kind": "paragraph",
  "number": "9",
  "heading": null,
  "text": "(1) This paragraph has effect in a case to which section 768B applies for determining the debits to be brought into account for the purposes of Part 5 of CTA 2009 (loan relationships) for—\n(a) the accounting period beginning immediately after the change in the ownership of the company; and\n(b) any subsequent accounting period.\n(2) The debits so brought into account shall not include the debits falling within paragraph 11 below to the extent (if at all) that the aggregate of—\n(a) the amount of those debits, and\n(b) the amount of any debits falling within that paragraph which have been brought into account for the purposes of that Part for any previous accounting period ending after the change in the ownership,\nexceeds the profits for the accounting period ending with the change in the ownership.\n(3) The reference in sub-paragraph (2) above to the profits is a reference to profits after making all deductions and giving all reliefs that for the purposes of corporation tax are made or given against the profits, including deductions and reliefs which under any provision are treated as reducing them for those purposes.",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Words in Sch. 28A para. 9(1) substituted (1.4.2009 with effect in accordance with s. 1329(1) of the amending Act) by Corporation Tax Act 2009 (c. 4), Sch. 1 para. 290(5)(a) (with Sch. 2 Pts. 1, 2)"
    },
    {
      "type": "F",
      "label": "F2",
      "text": "Words in Sch. 28A para. 9(2)(b) substituted (1.4.2009 with effect in accordance with s. 1329(1) of the amending Act) by Corporation Tax Act 2009 (c. 4), Sch. 1 para. 290(5)(b) (with Sch. 2 Pts. 1, 2)"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/1988/1/schedule/28A/paragraph/9",
    "retrieved_at": "2026-10-29T09:49:54.309394+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}