D9.102A Conditions

Corporate tax
Corporate tax | Commentary

D9.102A Conditions

Corporate tax | Commentary

Corporation tax regime

D9.102A Conditions

These provisions apply for corporation tax purposes. For details of the income tax regime see D9.116A–D9.119.

A person is liable to counteraction by HMRC under these provisions if three conditions are satisfied1:


    (a)     a person must be in a position to obtain, or must have obtained, a tax advantage (see D9.103);


    (b)     the tax advantage must be obtained or obtainable by that person in consequence of one or more transactions in securities or in consequence of the combined effect of the transaction or transactions (see D9.104);


    (c)     one of the prescribed circumstances must be present

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