SCHEDULES
SCHEDULE 23Manufactured payments: anti-avoidance
Section 572A
2
After section 572 insert—
572AMeaning 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.