[259M Countering the effect of avoidance arrangements]

[Chapter 13
Anti-Avoidance]

[259M  Countering the effect of avoidance arrangements]

[(1)     This section applies where—

(a)     relevant avoidance arrangements exist,

(b)     as a result of those arrangements, any person (whether party to the arrangements or not) would, apart from this section, obtain a relevant tax advantage, and

(c)     that person is—

(i)     within the charge to corporation tax at the time the person would obtain the relevant tax advantage, or

(ii)     would be within the charge to corporation tax at that time but for the relevant avoidance arrangements.

(2)     The relevant tax advantage is to be counteracted by making such adjustments to the person's treatment for corporation

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