Commentary

D1.8111 Contracts for unallowable purposes

Corporate tax
Corporate tax | Commentary

D1.8111 Contracts for unallowable purposes

Corporate tax | Commentary

D1.8111 Contracts for unallowable purposes

A derivative contract or a related transaction (see D1.840) includes an unallowable purpose if the purpose is not amongst the business or other commercial purposes of the company within the charge to corporation tax, or if one of the main purposes is a tax avoidance purpose1 ie the obtaining of a tax advantage within CTA 2010, s 1139.

The provision is not intended to deny relief for debits incurred in pursuit of the company's legitimate business or commercial purposes, but may apply to transactions which would otherwise offer no prospect of commercial or economic gain2.

Where the

To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to TolleyLibrary or register for a free trial