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Contents

Official guidance
Banking Manual

BKM504000 · The Code commitments – tax planning

  • BKM504050 · Introduction
  • BKM504100 · The “intentions of Parliament”
  • BKM504150 · Background
  • BKM504200 · Methodology
  • BKM504250 · Supporting genuine commercial activity
  • BKM504300 · Tax results for the bank
  • BKM504350 · Are the tax consequences of the proposed transaction inconsistent with the underlying economic consequences?
  • BKM504400 · The Legislation
  • BKM504450 · Established practice
  • BKM504500 · Reasonable belief test
  • BKM504550 · Code approaches
  • BKM504600 · Is the transaction within the GAAR?
  • BKM504650 · Technical challenge and legislative change
  • BKM504700 · Purpose tests
  • BKM504750 · Examples
  • BKM504800 · Promotion
  • BKM504850 · Remuneration packages and the meaning of “proper amounts of tax”
  1. The Code commitments – tax planning: contents
  2. The Code commitments – tax planning: the “intentions of Parliament”

BKM504100 | The Code commitments – tax planning: the “intentions of Parliament”

From HM Revenue & Customs · Banking Manual

This section sets out guidance on the interpretation of the phrase the “intentions of Parliament” as it is used in the Code and replaces the original supplementary guidance published when the Code was introduced on 9 December 2009.

For the purposes of this guidance, transactions that HMRC consider to be unacceptable transactions under the Code are called “Code Red” transactions. All other transactions are called “Code Green” transactions.

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