44 Extinguishment of BNFL losses for tax purposes

44  Extinguishment of BNFL losses for tax purposes

(1)     In relation to accounting periods beginning on or after the trigger date, all the relevant losses of every BNFL company arising before that date shall be treated for the purposes of corporation tax as extinguished.

(2)     The following are relevant losses of a BNFL company for the purposes of this section—

(a)     losses incurred by the company in a trade;

(b)     losses incurred by the company in a transaction a profit or gain from which would have been chargeable to tax [under or by virtue of any provision to which [section 1173 of the Corporation Tax Act 2010] (miscellaneous charges) applies];

(c)     excesses to be carried forward in the company's case under [section 1223 of the Corporation Tax Act 2009 (carrying

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