Part 13Additional relief for expenditure on research and development
Chapter 6Chapters 2 to 5: further provision
1084Artificially inflated claims for relief or tax credit
1
To the extent that a transaction is attributable to arrangements entered into wholly or mainly for a disqualifying purpose, it is to be disregarded for the purposes mentioned in subsection (2).
2
Those purposes are—
a
determining for an accounting period relief to which a company is entitled under F2Chapter 2 , and
b
determining for an accounting period R&D tax credits to which a company is entitled under Chapter 2.
3
Arrangements are entered into wholly or mainly for a “disqualifying purpose” if their main object, or one of their main objects, is to enable a company to obtain—
a
relief under F1Chapter 2 to which it would not otherwise be entitled,
b
relief under F1Chapter 2 of a greater amount than that to which it would otherwise be entitled,
c
an R&D tax credit under Chapter 2 to which it would not otherwise be entitled, or
d
an R&D tax credit under Chapter 2 of a greater amount than that to which it would otherwise be entitled.
4
In this section “arrangements” includes any scheme, agreement or understanding, whether or not legally enforceable.