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Official guidance
International Manual

INTM595000 · Arbitrage: legislation and principles - deductions

  • INTM595010 · Arbitrage: legislation and principles - deduction: persons affected by the deduction rules
  • INTM595020 · Expenses deducted more than once
  • INTM595030 · Deduction not matched by a taxable receipt
  • INTM595040 · Four conditions to be met for the arbitrage rules to apply
  • INTM595050 · Condition A - what is a scheme?
  • INTM595060 · Condition B - deduction for corporation tax
  • INTM595070 · Condition C - the main or a main purpose of achieving a UK tax advantage: Use of hybrids
  • INTM595075 · Condition C - the main or a main purpose of achieving a UK tax advantage: Examples on the application of Condition C
  • INTM595080 · Condition D - meaning of minimal
  • INTM595090 · Interaction with thin capitalisation agreements
  • INTM595100 · Interaction with other legislation
  • INTM595110 · Disclaiming a deduction
  1. Arbitrage: legislation and principles - deductions: Contents
  2. Arbitrage: legislation and principles - deductions: condition B - deduction for corporation tax

INTM595060 | Arbitrage: legislation and principles - deductions: condition B - deduction for corporation tax

From HM Revenue & Customs · International Manual

The deductions rules apply if and only if all of the four conditions A-D set out in s233 TIOPA 2010 are met.

Condition B is that the company must be in a position to claim or must have claimed a corporation tax deduction in respect of the transaction to which Condition A applies, or be in a position to set off or have set off against profits in an accounting period an amount relating to the transaction. S233(3) TIOPA 2010.

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