Corporation Tax Act 2009 section 1217LB

Transactions not entered into for genuine commercial reasons

Section 1217LB provides that transactions which are not entered into for genuine commercial reasons are to be disregarded when calculating theatre tax relief.

• Transactions attributable to arrangements not entered into for genuine commercial reasons must be ignored when calculating theatre tax relief
• This applies both to additional deductions under the theatre productions rules and to theatre tax credits
• This provision is separate from the rule against tax avoidance arrangements — it catches non-commercial transactions even where tax avoidance is not the main purpose
• The definitions of "arrangements" and "tax avoidance arrangements" are the same as those used in the associated anti-avoidance provision in section 1217LA