Chapter CFM92765

Published date16 April 2016
Record NumberCFM92765
CourtHM Revenue & Customs
IssuerHM Revenue & Customs
This guidance applies to worldwide group periods of account ending before or straddling 1 April 2017.
The type of schemes that are likely to be caught by the anti-avoidance rules covering Chapter 5 of TIOPA10/PT7

TIOPA10/S311 contains the anti-avoidance rules that are intended to prevent manipulation of the rules within Chapter 5. In direct terms this means the anti-avoidance rules are intended to counter schemes that

  • secure the payer is a relevant associate of the payee at the time of payment; or
  • secure the payer is resident and liable to tax in an EEA state (apart from the UK); or
  • secure the payer denied tax relief for the payment of the financing income amount.

The type of schemes that are likely to be caught by the anti-avoidance rules in TIOPA10/S311 include

  • Schemes that switch ownership of the company paying the financing income amount for a short period of time.
  • Schemes where the company paying the...

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