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Part 6 U.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)

Deduction noticesU.K.

233The deduction scheme conditionsU.K.

(1)This section sets out the deduction scheme conditions.

(2)Deduction scheme condition A is that the transaction to which the company is party forms part of a scheme that is a deduction scheme for the purposes of this Part (see sections 236 to 242).

(3)Deduction scheme condition B is that the scheme is such that for corporation tax purposes the company—

(a)is in a position to claim, or has claimed, an amount by way of deduction in respect of the transaction, or

(b)is in a position to set off, or has set off, an amount relating to the transaction against profits in an accounting period.

(4)Deduction scheme condition C is that the main purpose of the scheme, or one of its main purposes, is to achieve a UK tax advantage for the company.

(5)Deduction scheme condition D is that the amount of the UK tax advantage is more than minimal.