Commentary on Sections Overview Overview Section 334: Non-UK resident company ceasing to hold loan relationship for UK permanent establishment
1105.This section provides for a deemed disposal for fair value where an asset or liability representing a loan relationship of a non-UK resident company ceases to be held or owed by a permanent establishment in the United Kingdom other than as a result of a disposal etc. It is based on paragraph 10A(1), (1A) and (4) of Schedule 9 to FA 1996.