SCHEDULE 4 Avoidance Involving Profit Fragmentation Arrangements
Finance Act 2019 (2019 c 1) | Legislation

SCHEDULE 4 Avoidance Involving Profit Fragmentation Arrangements

Section 16

Introduction and overview

1

(1)     This Schedule contains provision about countering the tax effects of certain arrangements (“profit fragmentation arrangementsâ€).

(2)     Profit fragmentation arrangements involve the following parties—

(a)     a person resident in the United Kingdom (“the resident partyâ€),

(b)     an overseas person or entity (“the overseas partyâ€) who is not resident in the United Kingdom, and

(c)     an individual (a “related individualâ€) who is—

(i)     the resident party,

(ii)     a member of a partnership of which the resident party is a partner, or

(iii)     a participator in a company which is the resident party.

(3)     An “overseas person or entity†means—

(a)     a person abroad within the meaning given by section 718 of ITA 2007, or

(b)     a company, partnership, trust or other entity or arrangements established or having effect under the law of a country or territory outside the United Kingdom (regardless of whether it has legal personality as a body corporate).

(4)     Paragraphs 2 to 6 deal with the definition of profit fragmentation arrangements.

(5)     Paragraph 7 deals with the adjustments which must be made to counteract the effects of such arrangements.

(6)     Other provisions of this Schedule—

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