Sch 5 para 39
(1) This paragraph applies if— (a) on or after the commencement date a loss arises in connection with a loan relationship of a company, (b) the loss is wholly or partly referable to a time before the commencement date (“the pre-commencement time”), and (c) had the loss arisen at the pre-commencement time it would have been brought into account in accordance with Part 3 of ITTOIA 2005 in calculating the profits of the UK property business of the company. (2) Section 327 (disallowance of imported losses etc) does not apply in relation to so much of the loss as is referable to the pre-commencement time.