234Schemes achieving UK tax advantage for a companyU.K.
(1)For the purposes of section 233, a scheme achieves a UK tax advantage for a company if, in consequence of the scheme, the company is in a position to obtain, or has obtained—
(a)a relief or increased relief from corporation tax,
(b)a repayment or increased repayment of corporation tax, or
(c)the avoidance or reduction of a charge to corporation tax.
(2)In subsection (1)(a) “relief from corporation tax” includes a tax credit under section 1109 of CTA 2010 (tax credits for certain recipients of qualifying distributions) for the purposes of corporation tax.
(3)For the purposes of subsection (1)(c) avoidance or reduction may, in particular, be effected—
(a)by receipts accruing in such a way that the recipient does not pay or bear tax on them, or
(b)by a deduction in calculating profits or gains.