Taxation (International and Other Provisions) Act 2010 Explanatory Notes

Section 564Y: Provision not at arm’s length: relevant return

788.This section prevents any deduction in calculating profits for income tax purposes as a result of alternative finance arrangements where the rules about arrangements not at arm’s length in section 564H apply. It is based on section 52(4) and (5) of FA 2005. The corresponding rule for corporation tax is section 520 of CTA 2009.

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