BKLM620000 - Anti-avoidance: scope of the anti-avoidance rule

Paragraph 47 of Schedule 19

The anti-avoidance paragraph refers throughout to the 바카라 사이트˜relevant group바카라 사이트™ and 바카라 사이트˜relevant entity바카라 사이트™.

This should be read to include all chargeable entities and groups as defined in Chapter 2 (BKLM200000).

Paragraph 47(13) makes it clear that 바카라 사이트˜group바카라 사이트™ includes foreign banking groups and relevant non-banking groups but that where the entity in question is a foreign banking group or non-banking group, then where references to 바카라 사이트˜relevant group바카라 사이트™ are made, this refers to the relevant members of the group in the collective.

For foreign banking groups and relevant non-banking groups for the purposes of the anti-avoidance rules 바카라 사이트˜relevant member바카라 사이트™ has the same meaning as within paragraph 18 and 20 and includes a relevant foreign bank.

For chargeable periods ending on or after 1 January 2021 relevant member means:

  • a chargeable UK resident entity which is a member of the relevant group;
  • a UK sub-group of the relevant group; or
  • a relevant foreign bank which is a member of the relevant group