[917A Tax avoidance arrangements]

[Tax avoidance]

[917A  Tax avoidance arrangements]

[(1)     This section applies if and to the extent that—

(a)     a person (“the payer”) makes an intellectual property royalty payment,

(b)     the payment is received by a person (“the payee”) who is connected with the payer, and

(c)     the payment is made under DTA tax avoidance arrangements.

(2)     Any duty under Chapter 6 or 7 to deduct a sum representing income tax at any rate applies

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