Section 371QG | Anti-avoidance

(1)This section applies in relation to an accounting period (“the relevant accounting period”) of a CFC if—

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

(b)the main purpose, or one of the main purposes, of the arrangement is to obtain for any person a tax advantage within section 1139(2)(da) of CTA 2010 in relation to—

(i)the relevant accounting period, or

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

(2)The CFC's chargeable profits and creditable tax for the relevant accounting period are to be apportioned in accordance with section 371QC(2) (and not section 371QD if that section would otherwise apply).

(3)The apportionments must (in particular) be made in a way which, so far as practicable, counteracts the effects of the arrangement mentioned in subsection (1)(a) so far as those effects are referable to the purpose mentioned in subsection (1)(b).