http://www.legislation.gov.uk/ukpga/2010/4/section/730GCorporation Tax Act 2010An Act to restate, with minor changes, certain enactments relating to corporation tax and certain enactments relating to company distributions; and for connected purposes.texttext/xmlenStatute Law Database2026-04-16Expert Participation2026-03-18 Corporation Tax Act 2010s. 658(1)(d)(e)Finance Act 2010Sch. 6 para. 31Sch. 6 para. 35Corporation Tax Act 2010s. 357CHAFinance Act 2024Sch. 2 para. 14(7)Sch. 2 para. 16(2) PART 14B730G1This section applies if conditions A to E are met.2Condition A is that—afor the purposes of corporation tax a company has profits (“relevant profits”) for an accounting period,bthe relevant profits arise to the company as a result of any arrangements (“the tax arrangements”), andcin the absence of this section the company (“the relevant company”) would, for corporation tax purposes, be entitled to deduct from the relevant profits for the period an amount in respect of any relevant carried-forward losses.3Condition B is that—athe relevant company, or a company connected with that company, brings a deductible amount into account as a deduction for an accounting period, andbit is reasonable to assume that neither the company, nor any company connected with it, would have brought that amount into account as a deduction for that period but for the tax arrangements.4Condition C is that the main purpose, or one of the main purposes, of the tax arrangements is to secure a relevant corporation tax advantage or a relevant CFC charge advantage—afor the relevant company, orbif there are any companies connected with that company, for the relevant company and those connected companies (taken together).5In this section “relevant corporation tax advantage” means a corporation tax advantage involving—athe deductible amount mentioned in subsection (3), andbthe deduction of any relevant carried-forward losses from the relevant profits.5AIn this section “relevant CFC charge advantage” means a CFC charge advantage involving the deductible amount mentioned in subsection (3).6Condition D is that, at the time when the tax arrangements were entered into, it would have been reasonable to assume that the tax value of the tax arrangements would be greater than the non-tax value of the tax arrangements.7The “tax value” of the tax arrangements is the total value of—a any relevant corporation tax advantage, ...aaany relevant CFC charge advantage, andbany other economic benefits derived by—ithe relevant company, oriiif there are any companies connected with that company, the relevant company and those connected companies (taken together),as a result of securing the relevant corporation tax advantage or the relevant CFC charge advantage.8The “non-tax value” of the tax arrangements is the total value of any economic benefits, other than those falling within subsection (7)(a), (aa) or (b), derived by—athe relevant company, orbif there are any companies connected with that company, the relevant company and those connected companies (taken together),as a result of the tax arrangements.9Condition E is that the tax arrangements are not arrangements in relation to which section 269CK (banking companies: profits arising from tax arrangements to be disregarded) applies.10If this section applies, the relevant company is not entitled to deduct from the relevant profits any amount in respect of the relevant carried-forward losses.Pt. 14B inserted (with effect and application in accordance with Sch. 3 Pt. 2 of the amending Act) by Finance Act 2015 (c. 11), Sch. 3 para. 1Words in s. 730G(4) inserted (18.11.2015) (with effect in accordance with s. 37(7)(8) of the amending Act) by Finance (No. 2) Act 2015 (c. 33), s. 37(2)S. 730G(5A) inserted (18.11.2015) (with effect in accordance with s. 37(7)(8) of the amending Act) by Finance (No. 2) Act 2015 (c. 33), s. 37(3)Word in s. 730G(7)(a) substituted (18.11.2015) (with effect in accordance with s. 37(7)(8) of the amending Act) by Finance (No. 2) Act 2015 (c. 33), s. 37(4)(a)(i)Word in s. 730G(7)(a) omitted (18.11.2015) (with effect in accordance with s. 37(7)(8) of the amending Act) by virtue of Finance (No. 2) Act 2015 (c. 33), s. 37(4)(a)(ii)S. 730G(7)(aa) inserted (18.11.2015) (with effect in accordance with s. 37(7)(8) of the amending Act) by Finance (No. 2) Act 2015 (c. 33), s. 37(4)(b)Words in s. 730G(7)(b) inserted (18.11.2015) (with effect in accordance with s. 37(7)(8) of the amending Act) by Finance (No. 2) Act 2015 (c. 33), s. 37(4)(c)Word in s. 730G(8) inserted (18.11.2015) (with effect in accordance with s. 37(7)(8) of the amending Act) by Finance (No. 2) Act 2015 (c. 33), s. 37(5)