SCHEDULES
SCHEDULE 12Tax relief for expenditure on research and development
Part 5Supplementary provisions
Artificially inflated claims for deduction
16
(1)
To the extent that a transaction is attributable to arrangements entered into wholly or mainly for a disqualifying purpose, it shall be disregarded in determining for an accounting period the amount of any relief to which a company is entitled under this Schedule.
(2)
Arrangements are entered into wholly or mainly for a “disqualifying purpose” if their main object, or one of their main objects, is to enable a company to obtain relief under this Schedule to which it would not otherwise be entitled or of a greater amount than that to which it would otherwise be entitled.
(3)
In this paragraph “arrangements” includes any scheme, agreement or understanding, whether or not legally enforceable.