OT69020 | Transferable tax history - Miscellaneous - Anti-avoidance

The anti-avoidance provisions in FA19\Sch15\Para95 allow HMRC to amend a TTH election or amend or disallow a claim where a person has entered into arrangements which:

• attempt to get a repayment or an increased repayment earlier than would otherwise have been the case, or

• circumvent the intended limit of the legislation, or

• otherwise exploit shortcomings in the legislation

Where an amount of RFCT or SC is repaid, or relief is otherwise given, to a person, including the buyer or the seller, as a result of the provisions of the TTH legislation and the normal loss relief rules in Part 4 CTA 2010, no repayment may be made or relief given to any other person in respect of the same amount.