52U.K.After section 809ZF (which is inserted by CTA 2010) insert—
“Chapter 7U.K.Avoidance involving obtaining tax relief for interest
809ZGTax relief schemes and arrangements
(1)Relief is not to be given under any provision of the Income Tax Acts to a person in respect of a payment of interest if a tax relief scheme has been effected, or tax relief arrangements have been made, in relation to the transaction under which the interest is paid.
(2)Subsection (1) applies whether the tax relief scheme is effected, or the tax relief arrangements are made, before or after the transaction.
(3)A scheme is a tax relief scheme in relation to a transaction for the purposes of subsection (1) if it is such that the sole or main benefit that might be expected to accrue to the person from the transaction is the obtaining of a reduction in tax liability by means of relief under the Income Tax Acts.
(4)Arrangements are tax relief arrangements in relation to a transaction for the purposes of subsection (1) if they are such that the sole or main benefit that might be expected to accrue to the person from the transaction is the obtaining of a reduction in tax liability by means of relief under the Income Tax Acts.
(5)In this section “relief” means relief by way of—
(a)deduction in calculating profits or gains, or
(b)deduction or set off against income.”