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Legislation
Taxation (International and Other Provisions) Act 2010

Crossheading “The corporation tax assumptions”

  • Section 371SC What are “the corporation tax assumptions”?
  • Section 371SD UK residence etc
  • Section 371SE Close company
  • Section 371SF Claims and elections
  • Section 371SG Disapplication of assumption in section 371SF(1)
  • Section 371SH Elections under section 9A of CTA 2010
  • Section 371SI Modification of sections 6 and 7 of CTA 2010
  • Section 371SJ Elections for leases to be treated as long funding leases
  • Section 371SK Intangible fixed assets
  • Section 371SKA Restrictions on certain deductions: deductions allowances
  • Section 371SL Group relief etc
  • Section 371SLA Corporate interest restriction
  • Section 371SM Capital allowances
  • Section 371SN Unremittable overseas income
  • Section 371SO Tax advantages
  • Section 371SP Disguised interest: application of Chapter 2A of Part 6 of CTA 2009
  • Section 371SQ Shares accounted for as liabilities: application of section 521C of CTA 2009
  • Section 371SR Double taxation relief: countering effect of avoidance arrangements
  1. “The corporation tax assumptions”
  2. Double taxation relief: countering effect of avoidance arrangements

Section 371SR | Double taxation relief: countering effect of avoidance arrangements

From legislation.gov.uk

(1)This section applies if it is reasonable to suppose that, applying the corporation tax assumptions apart from this section, each of conditions A to D of section 82 (double taxation relief: conditions to be met for countering effect of avoidance arrangements) would or might be met in relation to the CFC in relation to the relevant accounting period.

(2)Assume that such adjustments are to be made as are necessary for counteracting what, applying the corporation tax assumptions apart from this section, would be the effects of the scheme or arrangement in question in the relevant accounting period that would be referable to the purpose referred to in condition B of section 82.

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