Part 3 “Defeat” in Respect of Abusive Tax Arrangements

Part 3 “Defeat” in Respect of Abusive Tax Arrangements

“Defeat” in respect of abusive tax arrangements

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T (within the meaning of paragraph 1) incurs a “defeat” in respect of abusive tax arrangements entered into by T (“the arrangements concerned”) if—

(a)     Condition A (in paragraph 5) is met, or

(b)     Condition B (in paragraph 6) is met.

Condition A

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(1)     Condition A is that—

(a)     T, or a person on behalf of T, has given HMRC a document of a kind listed in the Table in paragraph 1 of Schedule 24 to FA 2007 (returns etc),

(b)     the document was submitted on the basis that a tax advantage (“the relevant tax advantage”) arose from the

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