Taxation (International and Other Provisions) Act 2010

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The low profit margin exemption does not apply for a CFC's accounting period (“the relevant accounting period”) if—

(a)an arrangement is entered into at any time,

(b)in consequence of the arrangement, the low profit margin exemption would (apart from this section) apply for the relevant accounting period, and

(c)the main purpose, or one of the main purposes, of the arrangement is to secure that the low profit margin exemption applies—

(i)for the relevant accounting period, or

(ii)for that period and one or more other accounting periods of the CFC.]

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