CG40243 - Capital loss anti-avoidance rule - Definition of tax advantage
“Tax advantageâ€� has the meaning given in section 184D of the legislation. »Ê¹ÚÌåÓýappre are four legs to this definition, which cover relief, repayments, the amount of acharge, and the assessment of corporation tax.
If a tax advantage arises out of a transaction that is part of the arrangements, the legislation asks whether the main purpose or one of the main purposes of the arrangements (referred to as “a main purposeâ€� in this guidance) is to achieve a tax advantage. »Ê¹ÚÌåÓýapp purpose of the arrangements is determined by the purpose of the participants in entering into the arrangements. If any participant has a main purpose of achieving a tax advantage, that will constitute a main purpose of the arrangements.