Corporation Tax Act 2010 section 357YJ

Examples of results that may indicate exclusion not applicable

Section 357YJ provides examples of circumstances that may indicate arrangements designed to obtain a tax advantage should still be treated as relevant avoidance arrangements, despite a potential exclusion for commercial transactions.

• Reducing or eliminating restitution interest charges while the company actually enjoys other or greater economic profits from the same claim
• Preventing or delaying the recognition of profit or loss items that would otherwise appear, or appear earlier, in the company's accounts
• Ensuring a receipt is accounted for differently than it would have been without other transactions forming part of the arrangements
• The terms "arrangements" and "tax advantage" carry the same meanings as defined elsewhere in the restitution interest anti-avoidance rules