Part 4Loss relief
Chapter 7Losses from miscellaneous transactions
Supplementary
154AF3Anti-avoidance
1
Subsection (2) applies if—
a
a person makes a loss in a relevant transaction, and
b
that loss arises directly or indirectly in consequence of, or otherwise in connection with, relevant tax avoidance arrangements.
2
The person is not to be given loss relief under section 152 for the loss.
3
Subsection (4) applies if—
a
a person has income on which income tax is chargeable under, or by virtue of, a relevant section 1016 provision, and
b
that income arises directly or indirectly in consequence of, or otherwise in connection with, relevant tax avoidance arrangements.
4
The person is not to be given loss relief against that income under section 152.
5
In this section “relevant tax avoidance arrangements” means arrangements—
a
to which the person is party, and
b
the main purpose, or one of the main purposes, of which is to obtain a reduction in tax liability by means of loss relief under section 152.
6
In subsection (5) “arrangements” includes any agreement, understanding, scheme, transaction or series of transactions (whether or not legally enforceable).
155Time limit for claiming relief
1
2
But—
a
the question whether, and
b
if so, how much,