SCHEDULES
SCHEDULE 5Non-UK resident companies carrying on UK property businesses etc
PART 3Commencement and transitional provisions
Transitional provisions
I150
1
This paragraph applies if—
a
a company enters into an arrangement of a kind mentioned in paragraph 49(1),
b
the arrangements are effected by taking only ordinary commercial steps in accordance with a generally prevailing commercial practice,
c
the tax advantage that the arrangements secure is the benefit of a relief expressly conferred by Part 10 of TIOPA 2010 (corporate interest restriction), and
d
securing that tax advantage is wholly consistent with the policy objectives of that Part.
2
If the arrangement is entered into on or after 29 October 2018, the tax advantage is not to be counteracted by means of adjustments under paragraph 49.
3
In addition, the tax advantage is not to be counteracted by means of adjustments under section 461 of TIOPA 2010 irrespective of the date on which the arrangement was entered into.