Section 371DL | Exclusion: trading profits (anti-avoidance)

(1)This section applies if—

(a)a condition mentioned in section 371DF(1) is met, or

(b)the 50% condition mentioned in section 371DI is met in relation to an asset or risk (or a number of assets or risks taken together),

but it is reasonable to suppose that that would not be the case apart from an arrangement falling within subsection (3).

(2)The condition is to be taken not to be met or (as the case may be) not to be met in relation to the asset or risk (or the assets or risks taken together).

(3)An arrangement falls within this subsection if—

(a)the arrangement involves the CFC group organising (or reorganising) a significant part of its business in a particular way, and

(b)the main purpose, or one of the main purposes, of that organising (or reorganising) is to secure that—

(i)one or more of the conditions mentioned in section 371DF(1) are met, or

(ii)the 50% condition mentioned in section 371DI is met in relation to one or more assets or risks.