29 Disguised distribution arrangements involving derivative contracts
Finance Act 2014 (2014 c 26) | Legislation

29  Disguised distribution arrangements involving derivative contracts

(1)     In Chapter 11 of Part 7 of CTA 2009 (derivative contracts: tax avoidance), after section 695 (but before the following italic heading) insert—

“695A Disguised distribution arrangements involving derivative contracts

(1)     This section applies if—

(a)     a company (“A”) is a party to arrangements involving one or more derivative contracts (each of which is referred to in this section as a “specified contract”),

(b)     another company (“B”) is also a party to the arrangements (whether or not at the same time as A),

(c)     A and B are members of the same group,

(d)     the arrangements result in what is, in substance, a payment (directly or indirectly) from A to B of all or a significant part of the profits of the business of A or of a company which is a member of the same group as A or B (or both) (“the profit transfer”), and

(e)     the arrangements are not arrangements of a kind which companies carrying on the same kind of business as A would enter into in the ordinary course of that business.

(2)

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