82 Change of accounting practice: deferment of transitional adjustments

82  Change of accounting practice: deferment of transitional adjustments

(1)     This section applies where—

(a)     a company enters into a transaction on or after 14th December 2004, otherwise than in the ordinary course of its business,

(b)     as a result of the transaction it incurs a loss in respect of a loan relationship or derivative contract in respect of which, apart from this section, a debit would fall to be brought into account for tax purposes in a period of account beginning before 1st January 2005,

(c)     the sole or main purpose of the company in entering into the transaction at the time it did was to enable it to bring a debit into account for tax purposes in such a period,

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