Regulation 5 Corporation tax: loan relationships

For the purposes of Chapter 4 of Part 5 of CTA 2009 (continuity of treatment on transfers within groups or on reorganisations), in relation to a relevant transfer, ACo and BCo are to be treated as if, for the purposes of the transfer, they were members of the same group.

But a relevant transfer within paragraph (1) is not to be treated as a case within section 336 of CTA 2009 (transfers of loans on group transactions) for the purposes of section 344 of the Act (introduction).