Part 2Income tax, corporation tax and capital gains tax
Chapter 4Avoidance involving tax arbitrage
27Rule as to qualifying payment
(1)
The following provisions of this section apply in relation to a payment that is a qualifying payment in relation to a company if—
(a)
a notice specifying that payment is given to the company under section 26, and
(b)
when the notice is given, conditions A to E of section 26 are satisfied in relation to the company.
(2)
The company must compute (or recompute) for the purposes of corporation tax for the accounting period specified in the notice its income or chargeable gains, or its liability to corporation tax, as if the relevant part of the qualifying payment were F1a receipt of the company which is chargeable for that period under the charge to corporation tax on income.
(3)
The relevant part of the qualifying payment is the part by reference to which conditions C and D are satisfied; and, where conditions C and D are satisfied in relation to the whole of the qualifying payment, the relevant part is the whole of the qualifying payment.
(4)
In this section “qualifying payment” has the same meaning as in section 26.