SCHEDULES

SCHEDULE 15Tax treatment of financing costs and income

Part 6Anti-avoidance

47Schemes involving manipulation of rules in Part 2

1

A period of account of the worldwide group that, apart from this paragraph, is not within paragraph 2(1) is treated as within that provision if conditions A to C are met.

2

Condition A is that—

a

at any time before the end of the period, a scheme is entered into, and

b

if the scheme had not been entered into, the period would have been within paragraph 2(1).

3

Condition B is that the main purpose, or one of the main purposes, of any party to the scheme on entering into the scheme is to secure that the period is not within paragraph 2(1).

4

Condition C is that the scheme is not an excluded scheme.