BKM307750 | Bank loss restriction: targeted anti-avoidance rule: situations where the TAAR would not apply

HM Revenue & Customs would not consider the anti-avoidance rules to apply in the following situations:

• The arrangement does not create a tax advantage overall to the UK group

• The only reduction in tax is due to the claim and surrender of group relief between the two parties

• The value of the tax advantage is less than 50 percent of the net overall value to the group of entering into the arrangement.