Commentary

D7.4104 Anti-avoidance

Corporate tax
Corporate tax | Commentary

D7.4104 Anti-avoidance

Corporate tax | Commentary

D7.4104 Anti-avoidance

The transitional rules include a targeted anti-avoidance rule to prevent companies from taking steps to minimise the size of any transitional profit1. The rule potentially applies if a company enters into any arrangement or other activity that directly or indirectly affects the amount of the transitional rules and the main purpose, or one of the main purposes, of its action was an unallowable purpose which includes securing a corporation tax advantage for either itself or another company2.

In such cases HMRC may make such adjustments as are required to negate the tax advantage connected to the operation of the

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