110 “The insufficient economic substance condition”
Finance Act 2015 (2015 c 11) | Legislation

110  “The insufficient economic substance condition”

(1)     This section applies for the purposes of sections 80 and 86(2).

(2)     In this section “the first party” and “the second party” mean—

(a)     where this section applies for the purposes of section 80, C and P (within the meaning of section 80) respectively, and

(b)     where this section applies for the purposes of section 86(2), the foreign company and A (within the meaning of section 86) respectively.

(3)     The insufficient economic substance condition is met if one or more of subsections (4), (5) and (6) apply.

(4)     This subsection applies where—

(a)     the effective tax mismatch outcome is referable to a single transaction, and

(b)     it is reasonable to assume that the transaction was designed to secure the tax reduction,

unless, at the time of the making or imposition of the material provision, it was reasonable to assume that, for the first party and the second party (taken together) and taking account of all accounting periods for which the transaction was to have effect, the non-tax benefits

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