Corporation Tax Act 2010 section 357TE

Artificially inflated claims for additional deduction

Section 357TE applies anti-avoidance rules to prevent companies from artificially inflating claims for the Northern Ireland supplementary deduction available under the Northern Ireland regime.

• Existing anti-avoidance rules in CTA 2009 that target artificially inflated claims for additional deductions are extended to cover the Northern Ireland supplementary deduction.
• Where arrangements are in place that result in an inflated claim, HMRC can adjust the deduction to remove the artificial element.
• The provision ensures that the Northern Ireland supplementary deduction cannot be manipulated through contrived transactions or arrangements.
• The rule works by treating references to an additional deduction in the existing anti-avoidance legislation as also including the Northern Ireland supplementary deduction.