Part 15Film production

Chapter 3Film tax relief

Miscellaneous

1205Artificially inflated claims for additional deduction or film tax credit

1

So far as a transaction is attributable to arrangements entered into wholly or mainly for a disqualifying purpose, it is to be ignored in determining for any period—

a

any additional deduction which a company may make under this Chapter, and

b

any film tax credit to be given to a company.

2

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

an additional deduction under this Chapter to which it would not otherwise be entitled or of a greater amount than that to which it would otherwise be entitled, or

b

a film tax credit to which it would not otherwise be entitled or of a greater amount than that to which it would otherwise be entitled.

3

“Arrangements” includes any scheme, agreement or understanding, whether or not legally enforceable.