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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: tax results for the bank

BKM504300 | The Code commitments – tax planning: tax results for the bank

From HM Revenue & Customs · Banking Manual

Paragraph 3.1 of the Code begins by saying ‘Transactions should not be structured in a way that will have tax results for the bank ….’ In this context, the ‘tax results for the bank’ covers all the transactions and structures that have a significant impact upon the bank’s own tax position.

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