BKM307300 | Bank loss restriction: targeted anti-avoidance rule: meaning of tax value and non-tax value

CTA10/S269CK(6)&(7)

Condition C of the targeted anti-avoidance rule in CTA10/S269CK (BKM307100) is that the anticipated tax value of the tax arrangements must be greater than the anticipated non-tax value of the arrangements in order for the rule to apply.

Both the tax value and the non-tax value will be calculated on the basis of the company alone, or the company and any other connected companies party to the tax arrangements.

BKM307400 has guidance on the meaning of tax value

BKM307500 has guidance on the meaning of non-tax value