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