Corporation Tax Act 2009 section 1217RM

Transactions not entered into for genuine commercial reasons

Section 1217RM provides that transactions linked to arrangements lacking genuine commercial reasons must be disregarded when calculating orchestra tax relief.

• Any transaction attributable to arrangements not entered into for genuine commercial reasons is ignored when determining orchestra tax relief.
• This prevents the artificial inflation of relief claims through non-commercial arrangements.
• The rule does not apply to tax avoidance arrangements, which are dealt with separately under section 1217RL.
• The definitions of "arrangements" and "tax avoidance arrangements" are the same as those used in the separate tax avoidance arrangements provision.