Part 13Additional relief for expenditure on research and development
Chapter 7Relief for SMEs and large companies: vaccine research etc
Tax avoidance
1112Artificially inflated claims for relief or tax credit
(1)
To the extent that a transaction is attributable to arrangements entered into wholly or mainly for a disqualifying purpose, it is to be disregarded for the purposes mentioned in subsection (2).
(2)
Those purposes are—
(a)
determining for an accounting period relief to which a company is entitled under this Chapter, and
(b)
determining for an accounting period R&D tax credits to which a company is entitled under this Chapter.
(3)
Arrangements are entered into wholly or mainly for a “disqualifying purpose” if their main object, or one of their main objects, is to enable a company to obtain—
(a)
relief under this Chapter to which it would not otherwise be entitled,
(b)
relief under this Chapter of a greater amount than that to which it would otherwise be entitled,
(c)
an R&D tax credit under this Chapter to which it would not otherwise be entitled, or
(d)
an R&D tax credit under this Chapter of a greater amount than that to which it would otherwise be entitled.
(4)
In this section “arrangements” includes any scheme, agreement or understanding, whether or not legally enforceable.