375. Derecognition.

Where:

  1.  

    (1)     a company is at any time a party to tax avoidance arrangements1;

  2.  

    (2)     as a result of those arrangements, a creditor relationship to which the company is party, or any part of such a relationship is (in accordance with generally accepted accounting practice)2 derecognised by the company; and

  3.  

    (3)     the company continues to be a party to the creditor relationship immediately after the transaction or other event giving rise to the derecognition,

no debit that would otherwise be brought into account by the company for the purposes of these provisions as a result of the derecognition may be