Commentary

D4.744 Tax arbitrage—notices

Corporate tax
Corporate tax | Commentary

D4.744 Tax arbitrage—notices

Corporate tax | Commentary

D4.744 Tax arbitrage—notices

The provisions in this article were repealed from 1 January 2017. From 1 January 2017, the rules dealing with hybrid and other mismatches apply; see D4.701 onwards. The latter rules were introduced as part of the OECD BEPS action plan on international corporate tax avoidance.

If HMRC gives a notice under either of the provisions described in D4.741 and D4.743 (referred to in the legislation as 'Part 6 notices') the company has various options, depending upon when the notice was issued, as detailed below:

  1.  

    (a)     Part 6 notice issued before the company has made its tax return for the specified accounting period. The company may:

    1.  

      (1)     may make a

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