CTM08239 | Corporation Tax: management expenses: targeted anti-avoidance rule (TAAR) - outlying provisions
From HM Revenue & Customs · Company Taxation Manual
Various provisions of the Taxes Acts deem or treat particular expenses as expenses of management. Where amounts are simply deemed to be or are treated as expenses of management within then the remaining provisions of (for example capital exclusion), including S1248 automatically apply to the expenditure.
Other provisions of the Taxes Acts state that certain expenditure is deductible as expenses of management. ensures that these expenses are also subject to the TAAR.
Certain manufactured payments are deemed to be expenses of management by . has its own unallowable purpose rule. ensures that this specific unallowable purpose rule continues to apply in priority to S1248. This is not to say that S1248 cannot apply, but it will only apply in appropriate circumstances where does not. and S1220 do however have priority over , so the order is S1219 (2), then , and then if necessary .