395. Change in ownership of a shell company.

Where there is a change in the ownership of a shell company¹, the accounting period in which the change in ownership occurs ('the actual accounting period') is treated as two separate accounting periods ('notional accounting periods'), the first ending with the change and the second consisting of the remainder of the period². The amounts for the actual accounting period³ are apportioned to the two notional accounting periods⁴.

For the purpose of restricting the debits to be brought into account⁵ in respect of the company's loan relationships, the debits to be brought into account for the accounting period beginning immediately after