CG44103 - Targeted rules to prevent income to capital converter schemes by companies - definition of tax advantage

바카라 사이트œTax advantage바카라 사이트 has the meaning given in TCGA92/S184D. There are four legs tothis definition, which cover relief, repayments, the amount of a charge, and theassessment of corporation tax.

If a tax advantage arises out of a transaction that is part of the arrangements, thelegislation asks whether the main purpose or one of the main purposes of the arrangements(referred to as 바카라 사이트œa main purpose바카라 사이트 in this guidance) is to achieve a taxadvantage. The purpose of the arrangements is determined by the purpose of theparticipants in entering into the arrangements. If any participant has a main purpose ofachieving a tax advantage, that will constitute a main purpose of the arrangements.