Corporation Tax Act 2009 (c. 4)

Part 16 U.K. Companies with investment business

Chapter 4 U.K. Rules restricting deductions

1248 Expenses in connection with arrangements for securing a tax advantage U.K.

(1) No deduction is allowed under section 1219 for any particular expenses of management if any part of those expenses is incurred directly or indirectly in consequence of, or otherwise in connection with, any arrangements for securing a tax advantage.

(2) In subsection (1) “arrangements for securing a tax advantage” means arrangements the main purpose, or one of the main purposes, of which is to secure—

(a) the allowance of a deduction (or increased deduction) under section 1219, or

(b) any other tax advantage.

F1 (3) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

(4) The reference in subsection (1) to expenses of management includes amounts treated by any provision as deductible under section 1219.

(5) In this section—

• “arrangements” includes any agreement, understanding, scheme, transaction or series of transactions (whether or not legally enforceable),

• F2 ...

• “tax advantage” has the meaning given by [F3 section 1139 of CTA 2010].

Textual Amendments

F1 S. 1248(3) omitted (1.1.2014) by virtue of Finance Act 2013 (c. 29), Sch. 29 paras. 39(a), 52

F2 Words in s. 1248(5) omitted (1.1.2014) by virtue of Finance Act 2013 (c. 29), Sch. 29 paras. 39(b), 52

F3 Words in s. 1248(5) substituted (with effect in accordance with s. 1184(1) of the amending Act) by Corporation Tax Act 2010 (c. 4), s. 1184(1), Sch. 1 para. 689(b)(ii) (with Sch. 2)