xmlns:atom="http://www.w3.org/2005/Atom" xmlns:atom="http://www.w3.org/2005/Atom"

Part 6U.K.Tax arbitrage

Modifications etc. (not altering text)

C1Pt. 6 excluded by 2010 c. 4, s. 938N (as inserted (19.7.2011) by Finance Act 2011 (c. 11), Sch. 5 para. 2)

C2Pt. 6 excluded by 2010 c. 4, s. 938V(c) (as inserted (with effect in accordance with Sch. 20 para. 6 of the amending Act) by Finance Act 2013 (c. 29), Sch. 20 para. 3)

Receipt noticesU.K.

253Exception for dealersU.K.

(1)Receipt scheme condition D (see section 250(6)) is treated as not met if—

(a)the paying party (“P”) is a dealer,

(b)in the ordinary course of P's business, P incurs losses in respect of the transaction or transactions forming part of the scheme to which P is party, and

(c)the amount by reference to which that condition would be met, but for this section, is an amount in respect of those losses.

(2)In subsection (1) “dealer” means a person who—

(a)is charged to corporation tax under Part 3 of CTA 2009 (trading income) in respect of distributions of companies that are received in the course of a trade not consisting of insurance business, or

(b)would be so charged if UK resident.

(3)In this section “the paying party” has the same meaning as in section 250.