Section 371MC | Anti-avoidance

The low profit margin exemption does not apply for a CFC's accounting period (“the relevant accounting period”) if—^F1

(a)an arrangement is entered into at any time,^F1

(b)in consequence of the arrangement, the low profit margin exemption would (apart from this section) apply for the relevant accounting period, and^F1

(c)the main purpose, or one of the main purposes, of the arrangement is to secure that the low profit margin exemption applies—^F1

(i)for the relevant accounting period, or^F1

(ii)for that period and one or more other accounting periods of the CFC.^F1