»Ê¹ÚÌåÓýapp

Paragraph 2 Schedule 4 Finance Act 2019 defines the “Profit Fragmentation Arrangements� to which the rules apply.

For there to be “Profit Fragmentation Arrangements� four conditions must be satisfied:

• »Ê¹ÚÌåÓýappre exists a Material Provision (as defined in the legislation)
• »Ê¹ÚÌåÓýappre is a Transfer of Value as a result of that provision
• »Ê¹ÚÌåÓýapp value of the transfer is not the same as would result in an Arm’s Length Transfer between independent parties
• One of the Enjoyment Conditions is met in relation to the related individual

»Ê¹ÚÌåÓýappse conditions are discussed in more detail in the following pages.

»Ê¹ÚÌåÓýapp arrangements will not be “Profit Fragmentation Arrangementsâ€� if either of the Exception Conditions discussed at INTM610140 is met.