Section 379
| the arrangements (in Chapter 2 of Part 2) | section 21(1) |
| chargeable gain (in Part 2 so far as relating to capital gains tax) | section 105 |
| double taxation arrangements (in Part 2) | section 2(4) |
| double taxation arrangements (in Part 3) | section 136(2) |
| foreign tax (in Chapter 2 of Part 2) | section 21(1) |
| [F1insurance company | section 65 of FA 2012 (as applied by section 141(2) of that Act)] |
| international arrangements (in Part 3) | section 136(3) |
| [F1long-term business | section 63 of FA 2012 (as applied by section 141(2) of that Act)] |
| the non-UK territory (in Chapter 2 of Part 2) | section 21(1) |
| the Savings Directive (in Part 3) | section 136(4) |
| savings income (in Part 3) | section 136(5) |
| special withholding tax (in Part 3) | section 136(6) |
| tax not chargeable directly or by deduction (in Chapter 2 of Part 2) | sections 17(3) and 20(4) |
| tax payable or chargeable (in Chapter 2 of Part 2) | sections 17(3) and 20(4) |
| tax payable or paid under the law of a territory outside the United Kingdom (in Chapter 2 of Part 2, except section 29, in its application to relief under unilateral relief arrangements) | section 8(2) |
| underlying tax (in Chapter 2 of Part 2) | section 21(1) |
| unilateral relief arrangements (in Part 2) | section 8(1) |
Textual Amendments
F1Words in Sch. 11 Pt. 1 inserted (17.7.2012) by Finance Act 2012 (c. 14), Sch. 16 para. 244
| the actual provision (in Part 4) | section 149 |
| the advantaged person (in Chapter 4 of Part 4) | section 174(1) |
| the affected persons (in Part 4) | section 149(1), (2) |
| the arm's length provision (in Part 4) | section 151 |
| control (of a body corporate or firm) (in Part 4) | section 217 |
| the disadvantaged person (in Chapter 4 of Part 4) | section 174(1) |
| firm (in Part 4) | section 217(8) |
| the guarantor company (in Chapter 5 of Part 4) | section 191(5) |
| the issuing company (in Chapter 5 of Part 4) | section 191(5) |
| losses (in Part 4) | section 156(1) |
| medium-sized enterprise (in Chapter 3 of Part 4) | section 172 |
| participation (direct or indirect) in the management, control or capital of another person (in Part 4) | Chapter 2 of Part 4 |
| potential advantage in relation to United Kingdom taxation (in Part 4) | section 155(2) |
| profits (in Part 4) | section 156(2) |
| the relevant activities (in Part 4) | section 216 |
| relevant notice (in Chapter 4 of Part 4) | section 190 |
| section 182 claim (in Part 4) | section 181(3) |
| the security (in Chapter 5 of Part 4) | section 191(5) |
| small enterprise (in Chapter 3 of Part 4) | section 172 |
| transaction, and series of transactions (in Part 4) | section 150 |
| transfer pricing notice (in Chapter 3 of Part 4) | section 168(2) |
| advance pricing agreement (in Part 5) | section 218(1) |
| the Commissioners (in Part 5) | section 230 |
| officer (in Part 5) | section 230 |
Textual Amendments
F2Sch. 11 Pt. 4 omitted (with effect in accordance with Sch. 10 para. 22 of the amending Act) by virtue of Finance Act 2016 (c. 24), Sch. 10 para. 16
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
Textual Amendments
F3Sch. 11 Pt. 4A inserted (15.9.2016) by Finance Act 2016 (c. 24), Sch. 10 para. 17
| arrangement (in Part 6A) | section 259NF |
| CFC and CFC charge (in Part 6A) | section 259B(4) |
| the Commissioners (in Part 6A) | section 259NF |
| control group (in Part 6A) | section 259NB |
| deduction period (in Chapter 10 of Part 6A) | section 259JA(5)(a) |
| dual resident company (in Chapter 10 of Part 6A) | section 259JA(3) |
| dual territory double deduction amount (in Chapter 10 of Part 6A) | section 259JA(5) |
| dual territory double deduction (in Chapter 11 of Part 6A) | section 259KB |
| excessive PE deduction (in Chapter 6 of Part 6A) | section 259FA(8) |
| excessive PE deduction (in Chapter 11 of Part 6A) | section 259KB |
| financial instrument (in Part 6A) | section 259N |
| foreign CFC and foreign CFC charge (in Part 6A) | section 259B(4) |
| foreign deduction period (in Chapter 10 of Part 6A) | section 259JA(5)(b) |
| hybrid entity (in Part 6A) | section 259BE |
| hybrid entity deduction period (in Chapter 9 of Part 6A) | section 259IA(2)(a) |
| hybrid entity double deduction amount (in Chapter 9 of Part 6A) | section 259IA(4) |
| hybrid or otherwise impermissible deduction/non-inclusion mismatch (in Chapter 3 of Part 6A) | section 259CB |
| hybrid payee (in Chapter 7 of Part 6A) | section 259GA(3) |
| hybrid payee deduction/non-inclusion mismatch (in Chapter 7 of Part 6A) | section 259GB |
| hybrid payer (in Chapter 5 of Part 6A) | section 259EA(3) |
| hybrid payer deduction/non-inclusion mismatch (in Chapter 5 of Part 6A) | section 259EB |
| hybrid transfer arrangement (in Chapter 4 of Part 6A) | section 259DB |
| hybrid transfer deduction/non-inclusion mismatch (in Chapter 4 of Part 6A) | section 259DC |
| imported mismatch payment (in Chapter 11 of Part 6A) | section 259KA(2) |
| imported mismatch arrangement (in Chapter 11 of Part 6A) | section 259KA(2) |
| investor (in Part 6A) | section 259BE(4) |
| investor deduction period (in Chapter 9 of Part 6A) | section 259IA(2)(b) |
| investor jurisdiction (in Part 6A) | section 259BE(4) |
| mismatch payment (in Chapter 11 of Part 6A) | section 259KA(6) |
| multinational company (in Chapter 6 of Part 6A) | section 259FA(3) |
| multinational company (in Chapter 8 of Part 6A) | section 259HA(4) |
| multinational payee deduction/non-inclusion mismatch (in Chapter 8 of Part 6A) | section 259HB |
| ordinary income (in Part 6A) | sections 259BC and 259BD |
| over-arching arrangement (in Chapter 11 of Part 6A) | section 259KA(5) |
| P (in Chapter 11 of Part 6A) | section 259KA(3) |
| parent jurisdiction (in Chapter 6 of Part 6A) | section 259FA(3)(a) |
| parent jurisdiction (in Chapter 8 of Part 6A) | section 259HA(4)(a) |
| parent jurisdiction (in Chapter 10 of Part 6A) | section 259JA(4)(b)(ii) |
| payee (in Part 6A) | section 259BB(6) |
| payee jurisdiction (in Part 6A) | section 259BB(9) |
| payer (in Part 6A) | section 259BB(1)(a) or (2) |
| payment (in Part 6A) | section 259BB(1) |
| payment period (in Part 6A) | section 259BB(1)(b) or (2) |
| PE jurisdiction (in Chapter 8 of Part 6A) | section 259HA(4)(b) |
| PE jurisdiction (in Chapter 10 of Part 6A) | section 259JA(4)(a) |
| PE jurisdiction (in Chapter 11 of Part 6A) | section 259KB(3)(a) |
| permanent establishment (in Part 6A) | section 259BF |
| quasi-payment (in Part 6A) | section 259BB(2) to (5) |
| related (in Part 6A) | section 259NC |
| relevant deduction (in Part 6A) | section 259BB(1)(b) or (2)(a) |
| relevant investment fund (in Part 6A) | section 259NA |
| relevant mismatch (in Chapter 11 of Part 6A) | section 259KA(6) |
| relevant multinational company (in Chapter 10 of Part 6A) | section 259JA(4) |
| relevant PE period (in Chapter 6 of Part 6A) | section 259FA(4) |
| series of arrangements (in Chapter 11 of Part 6A) | section 259KA(5) |
| substitute payment (in Chapter 4 of Part 6A) | section 259DB(5) |
| tax (in Part 6A) | section 259B |
| taxable period (in Part 6A) | section 259NF |
| taxable profits (in Part 6A) | sections 259BC(2) and 259BD(5) |
| underlying instrument (in Chapter 4 of Part 6A) | section 259DB(3) |
| underlying return (in Chapter 4 of Part 6A) | section 259DB(5)(b)] |
| amount disclosed in financial statements for a period (in Part 7 except Chapter 2) | section 350 |
| amounts disclosed in financial statements (in Part 7) | section 349 |
| available amount (in Part 7) | section 332 |
| the Commissioners (in Part 7) | section 353 |
| company to which Chapter 3 applies (in Chapter 3 of Part 7) | section 275 |
| company to which Chapter 4 applies (in Chapter 4 of Part 7) | section 287 |
| corporate entity (in Part 7) | section 340 |
| [F4dual resident investing company (in Chapter 3 of Part 7) | section 275A] |
| EEA territory (in Chapter 5 of Part 7) | section 301(2) |
| effective interest method (in Part 7) | section 351 |
| the end date (in Chapter 2 of Part 7) | section 262(8) |
| entity (in Part 7) | section 351 |
| excluded scheme (in Chapter 6 of Part 7) | section 312(2), (3) |
| [F5FCA Handbook (in Part 7) | Section 353] |
| financial instrument (in Chapter 2 of Part 7) | section 270(1) |
| financial statements of the worldwide group (in Part 7) | section 346(2) |
| financing expense amount (in Part 7) | section 313 |
| financing income amount (in Chapter 5 of Part 7 and section 311) | section 305 |
| financing income amount (in the rest of Part 7) | section 314 |
| FISMA 2000 (in Part 7) | section 353 |
| F6. . . | F6. . . |
| group (in Part 7) | section 338 |
| [F4group securitisation company (in Chapter 2 of Part 7) | section 273A] |
| HMRC (in Part 7) | section 353 |
| insurance activities (in Chapter 2 of Part 7) | section 269 |
| insurance-related activities (in Chapter 2 of Part 7) | section 269 |
| large in relation to a group (in Part 7) | section 344 |
| lending activities (in Chapter 2 of Part 7) | section 268 |
| net financing deduction (in Part 7) | section 329 |
| parent (in Part 7) | section 351 |
| period of account of the worldwide group (in Part 7) | section 346(3) |
| [F5PRA Handbook (in Part 7) | section 353] |
| qualifying activities (in Chapter 2 of Part 7) | section 267 |
| relevant accounting period (in Part 7) | section 352 |
| relevant associate (in Chapter 5 of Part 7) | section 300 |
| relevant dealing (in Chapter 2 of Part 7) | section 270(2), (3) |
| relevant group company (in Part 7) | section 345 |
| relevant non-corporate entity (in Part 7) | section 341 |
| the relevant period of account (in Chapter 3 of Part 7) | section 274(1) |
| the relevant period of account (in Chapter 4 of Part 7) | section 286(1) |
| the reporting body (in Chapter 3 of Part 7) | section 277 |
| the reporting body (in Chapter 4 of Part 7) | section 289 |
| scheme (in Chapter 6 of Part 7) | section 312(1) |
| the start date (in Chapter 2 of Part 7) | section 262(8) |
| subsidiary (in Part 7) | section 351 |
| tax of a territory outside the United Kingdom (in Chapter 5 of Part 7) | section 304(2), (3) |
| tax of the United Kingdom (in Chapter 5 of Part 7) | section 304(1) |
| tax-resident (in Chapter 5 of Part 7) | section 301(1) |
| tested expense amount (in Part 7) | section 329 |
| tested income amount (in Part 7) | section 330 |
| total disallowed amount (in Chapter 3 of Part 7) | section 274(2) |
| total disallowed amount (in Chapter 4 of Part 7) | section 286(2) |
| UK group company (in Part 7) | section 345 |
| [F4UK net debt (in Chapter 2 of Part 7) | section 262] |
| UK trading income (in Chapter 2 of Part 7) | section 266(3) |
| ultimate parent (in Part 7) | section 339 |
| [F4worldwide gross debt (in Chapter 2 of Part 7) | section 264] |
| the worldwide group (in Part 7) | section 337 |
| worldwide trading income (in Chapter 2 of Part 7) | section 266(3) |
Textual Amendments
F4Words in Sch. 11 Pt. 5 inserted (retrospectively) by Finance (No. 3) Act 2010 (c. 33), Sch. 5 paras. 35, 36(1)
F5Sch. 11 Pt. 5 entries inserted (1.4.2013) by The Financial Services Act 2012 (Consequential Amendments) Order 2013 (S.I. 2013/636), art. 1(2), Sch. para. 13(6)(b)
F6Sch. 11 Pt. 5 entry omitted (1.4.2013) by virtue of The Financial Services Act 2012 (Consequential Amendments) Order 2013 (S.I. 2013/636), art. 1(2), Sch. para. 13(6)(a)
| participant (in Part 8) | section 362(1) |
| participation (in Part 8) | section 362(2) |
| part of umbrella arrangements (in Part 8) | section 363(2) |
| umbrella arrangements (in Part 8) | section 363(1) |