11U.K.In section 809S of ITA 2007 (remittance basis: anti-avoidance provisions relating to transfers of mixed funds), for subsection (4) substitute—
“(4)Income tax advantage” means—
(a)a relief from income tax or increased relief from income tax,
(b)a repayment of income tax or increased repayment of income tax,
(c)the avoidance or reduction of a charge to income tax or an assessment to income tax, or
(d)the avoidance of a possible assessment to income tax;
and for this purpose “relief from income tax” includes a tax credit.
(4A)For the purposes of subsection (4)(c) and (d) it does not matter whether the avoidance or reduction is effected—
(a)by receipts accruing in such a way that the recipient does not pay or bear income tax on them, or
(b)by a deduction in calculating profits or gains.”