{
  "url": "https://openlegislation.uk/railways-act-2005/schedule-10/paragraph-18",
  "json_url": "https://openlegislation.uk/railways-act-2005/schedule-10/paragraph-18.json",
  "legislation": "ukpga/2005/14",
  "legislation_title": "Railways Act 2005",
  "legislation_url": "https://openlegislation.uk/railways-act-2005",
  "path": "schedule/10/paragraph/18",
  "kind": "paragraph",
  "number": "18",
  "heading": null,
  "text": "(1) For the purposes of the application of Part 5 of the Corporation Tax Act 2009 (loan relationships) in relation to a relevant transfer, the transferee and the transferor are to be treated as if, at the time of the transfer, they were members of the same group.\n(2) In sub-paragraph (1), the reference to being members of the same group must be construed in accordance with section 335(6) of that Act.",
  "extent": "E+W+S",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Words in Sch. 10 para. 18(1) substituted (with effect in accordance with s. 1329(1) of the amending Act) by Corporation Tax Act 2009 (c. 4), s. 1329(1), Sch. 1 para. 667(5)(a) (with Sch. 2 Pts. 1, 2)"
    },
    {
      "type": "F",
      "label": "F2",
      "text": "Words in Sch. 10 para. 18(2) substituted (with effect in accordance with s. 1329(1) of the amending Act) by Corporation Tax Act 2009 (c. 4), s. 1329(1), Sch. 1 para. 667(5)(b) (with Sch. 2 Pts. 1, 2)"
    },
    {
      "type": "I",
      "label": "I1",
      "text": "Sch. 10 para. 18 in force at 8.6.2005 by S.I. 2005/1444, art. 2(1), Sch. 1"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2005/14/schedule/10/paragraph/18",
    "retrieved_at": "2026-10-29T09:16:06.853495+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."
}