SCHEDULES
SCHEDULE 15

Tax treatment of financing costs and income
Part 6

Anti-avoidance

Schemes involving manipulation of rules in Part 2
47
1
A period of account of the worldwide group that, apart from this paragraph, is not within paragraph 2(1) is treated as within that provision if conditions A to C are met.
2
Condition A is that—
a
at any time before the end of the period, a scheme is entered into, and
b
if the scheme had not been entered into, the period would have been within paragraph 2(1).
3
Condition B is that the main purpose, or one of the main purposes, of any party to the scheme on entering into the scheme is to secure that the period is not within paragraph 2(1).
4
Condition C is that the scheme is not an excluded scheme.
Sch. 15 modified (21.7.2009 retrospective) by Finance (No. 3) Act 2010 (c. 33), Sch. 5 para. 36(2)