Part 11Manufactured payments and repos

Chapter 2Manufactured payments

Introduction

572AF1Meaning of “avoidance arrangements”

1

In this Chapter “avoidance arrangements” means any arrangements the main purpose, or one of the main purposes, of which is to secure a deduction for the purposes of income tax, or any other income tax advantage, for any person.

2

In subsection (1) “arrangements” includes any agreement, understanding, scheme, transaction or series of transactions (whether or not legally enforceable).

3

In subsection (1) “income tax advantage” means—

a

a relief from income tax or increased relief from income tax,

b

a repayment of income tax or increased repayment of income tax,

c

the avoidance, reduction or delay of a charge to income tax or assessment to income tax, or

d

the avoidance of a possible assessment to income tax.

4

In subsection (3)(a) “relief from income tax” includes a tax credit.

5

For the purposes of subsection (3)(c) or (d) it does not matter whether the avoidance or reduction is effected—

a

by receipts accruing in such a way that the recipient does not pay or bear income tax on them, or

b

by a deduction in calculating profits or gains.