Part 8Oil activities

Chapter 4Calculation of profits

Tariff receipts etc

F1291BTariff receipts: counteraction of avoidance arrangements

(1)

Subsection (2) applies if an arrangement has been entered into, the main purpose or one of the main purposes of which is to obtain a tax advantage by reference to section 291.

(2)

The relevant tax advantage is to be counteracted by the making of such adjustments as are just and reasonable.

(3)

Any adjustments required to be made under this section (whether or not by an officer of Revenue and Customs) may be made by way of—

(a)

an assessment,

(b)

the modification of an assessment,

(c)

amendment or disallowance of a claim,

or otherwise.

(4)

In this section—

“arrangement” includes any agreement, understanding, scheme, transaction or series of transactions (whether or not legally enforceable);

“tax advantage” has the meaning given by section 1139.