Skip to content
Solved
SearchBrowse
Sign in

Contents

Official guidance
International Manual

INTM595500 · Arbitrage: legislation and principles - receipts

  • INTM595510 · Aim and effect of the legislation
  • INTM595520 · Five conditions need to be met for the receipts rule to apply
  • INTM595530 · Receipts rule conditions
  • INTM595540 · Meaning of scheme for receipts cases
  • INTM595550 · What is reasonable expectation?
  • INTM595560 · What is a contribution to the capital of a company?
  • INTM595570 · Role of the receipts rule in reinforcing other financial avoidance rules
  1. Arbitrage: legislation and principles - receipts: contents
  2. Arbitrage: legislation and principles - receipts: meaning of scheme for receipts cases

INTM595540 | Arbitrage: legislation and principles - receipts: meaning of scheme for receipts cases

From HM Revenue & Customs · International Manual

As with the deductions rules, it is necessary that the arrangements giving rise to the arbitrage constitute a scheme. However, whereas it is necessary for the deductions rules that the scheme is a qualifying scheme which includes a hybrid entity or instrument, it is not necessary (for the receipts rules to apply) for the scheme to be a qualifying scheme.

PreviousNext
PrivacyTerms