INTM595010 - Arbitrage: legislation and principles - deduction: persons affected by the deduction rules

»Ê¹ÚÌåÓýapp anti-arbitrage rules apply to disallow a UK corporation tax deduction where -

  • there is a scheme which meets the conditions in s233 Taxation (International and Other Provisions) Act 2010 (TIOPA 2010) and
  • where there is a payment which qualifies for a tax deduction and
  • there exists a corresponding payee who is not taxed on the receipt, or the tax charge is reduced, or where there arises another tax deduction for the same item of expenditure.

»Ê¹ÚÌåÓýapp deduction rules apply to companies within the charge to corporation tax. This includes UK resident companies and the UK permanent establishments of overseas companies. (s232(1) TIOPA 2010).