Commentary

D4.727 Countering avoidance arrangements

Corporate tax
Corporate tax | Commentary

D4.727 Countering avoidance arrangements

Corporate tax | Commentary

D4.727 Countering avoidance arrangements

As might be expected within such complex anti avoidance provisions there is also a general 'catch all' anti-avoidance rule. This provides that any person who is within the charge to corporation tax (or who would be but for the avoidance) and obtains a 'relevant tax advantage' as a result of 'relevant avoidance arrangements' will have the relevant tax advantage counteracted by the making of just and reasonable adjustments to their corporation tax treatment1. The two key concepts are:

  1.  

    (a)     A 'relevant tax advantage' is obtained if a person avoids the restriction of a deduction or the

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