Corporation Tax Act 2010 (c. 4)

Part 15 U.K. Transactions in securities

Introduction U.K.

731 Overview of Part U.K.

(1) This Part makes provision for counteracting corporation tax advantages obtained or obtainable by companies to which section 733 applies in respect of a transaction or transactions in securities.

(2) See section 746 (counteraction notices) for the way in which the corporation tax advantages may be counteracted.

732 Meaning of “corporation tax advantage” U.K.

(1) In this Part “corporation tax advantage” means—

(a) a relief from corporation tax or increased relief from corporation tax,

(b) a repayment of corporation tax or increased repayment of corporation tax,

(c) the avoidance or reduction of a charge to corporation tax or an assessment to corporation tax, or

(d) the avoidance of a possible assessment to corporation tax.

(2) For the purposes of subsection (1)(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 corporation tax on them, or

(b) by a deduction in calculating profits or gains.