Section 67 | Deductions for employee liabilities

(1)ITEPA 2003 is amended as follows.

(2)In section 346 (deduction for employee liabilities), after subsection (2) insert—

(2A)Nor is a deduction allowed for a payment which falls within paragraph A, B or C if the payment is made in pursuance of arrangements the main purpose, or one of the main purposes, of which is the avoidance of tax.

(3)After section 556 insert—

556ADeductible payments made pursuant to tax avoidance arrangements

(4)The amendments made by this section have effect in relation to payments made on or after 12 January 2009 (irrespective of when the arrangements are made).