Income Tax (Trading and Other Income) Act 2005 section 608Z

Interpretation of Chapter: general

Section 608Z provides definitions of the key terms used throughout Chapter 2A, which deals with the taxation of UK-derived amounts.

• The section defines a wide range of terms used in Chapter 2A, including "arrangements", "the Commissioners", "control group", "double taxation arrangements", "designer tax provisions", "full treaty territory", "intangible property", "related", "resident", "tax", "tax advantage", "UK-derived amount" and "UK sales".
• "Arrangements" is given a deliberately broad meaning, covering any agreements, understandings, schemes, transactions or series of transactions, whether or not they are legally enforceable.
• "Tax" in this context means a tax on income, similar in nature to UK income tax or corporation tax, that is payable or has been paid under the laws of a territory outside the United Kingdom.
• "Designer tax provisions" are regulations that HMRC consider to be provisions helping individuals significantly influence their tax liabilities in relation to UK-derived amounts.