30 Avoidance schemes involving the transfer of corporate profits

30  Avoidance schemes involving the transfer of corporate profits

(1)     In Chapter 1 of Part 20 of CTA 2009 (general calculation rules: restriction on deductions), after section 1305 insert—

“1305A Avoidance schemes involving the transfer of corporate profits

(1)     This section applies if—

(a)     two companies (“A” and “B”) are party to any arrangements (whether or not at the same time),

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

(c)     the arrangements result in what is, in substance, a payment (directly or indirectly) from A to B of all or a significant part of

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