Taxation (International and Other Provisions) Act 2010 section 247

Cases where payee treated as having reduced liability as a result of scheme

Section 247 provides further detail on the circumstances in which a payee is treated as having a reduced tax liability as a result of a scheme, expanding on one of the conditions set out in section 245.

• This section elaborates on condition C from section 245, which concerns situations where the payee's tax liability is reduced because of a scheme
• A payee is treated as having a reduced liability where arrangements or transactions forming part of a scheme result in lower tax being payable than would otherwise be the case
• The provision targets situations where the payee's effective tax burden on the income received is artificially lowered through structured arrangements
• The section works alongside the broader anti-avoidance framework in sections 244 to 246 to ensure that treaty benefits are not exploited through schemes designed to reduce the payee's ultimate tax exposure