[165E Transaction to obtain tax advantage]

[165E  Transaction to obtain tax advantage]

[(1)     Allowances under this Part are restricted under subsection (5) if—

(a)     a person (“R”) who is carrying on, or has ceased to carry on, a ring fence trade enters into a transaction with another person (“S”),

(b)     S receives from R consideration for services provided in pursuance of the transaction,

(c)     all or part of that consideration is decommissioning expenditure, and

(d)     the transaction either has an avoidance purpose, or is part of,

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