Part IV Reductions in United Kingdom Tax and Diversion of Profits

Part IV Reductions in United Kingdom Tax and Diversion of Profits

16

(1)     The provisions of this Part of this Schedule have effect for the purposes of section 748(3).

(2)     Any reference in paragraphs 17 and 18 below to a transaction—

(a)     is a reference to a transaction [the results of which are] reflected in the profits arising in an accounting period of a controlled foreign company; and

(b)     includes a reference to [two or more transactions taken together, the results of at least one of which are so reflected].

17

(1)     A transaction achieves a reduction in United Kingdom tax if, had the transaction not been effected, any person—

(a)     would have been liable

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