Corporation Tax Act 2010 section 730H

Interpretation of section 730G

Section 730H provides the definitions of key terms used in section 730G, which deals with the disallowance of deductions for carried-forward losses in tax avoidance situations.

• "Arrangements" is defined very broadly to include any agreement, understanding, scheme, transaction, or series of transactions, whether or not they are legally enforceable.
• "Corporation tax advantage" covers a wide range of tax benefits, including obtaining or increasing relief or repayments, avoiding or reducing charges or assessments, avoiding a possible assessment, or deferring a payment or accelerating a repayment of corporation tax.
• "Deductible amount" encompasses trade expenses, property business expenses, investment management expenses, and certain non-trading debits from loan relationships, derivative contracts, and intangible fixed assets, but excludes amounts already factored into relevant tax written-down value calculations under the allowance-buying rules and research and development allowances treated as trade expenses.
• When section 730G refers to bringing an amount into account "as a deduction", this means using it either in calculating profits, losses, or other amounts for corporation tax purposes, or deducting it from profits or other amounts that are chargeable to corporation tax.