Policy paper
Avoidance schemes involving the transfer of profits
This Tax Information and Impact Note explains the operation of s1305A for avoidance schemes involving the transfer of corporate profits.
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Details
Guidance on avoidance schemes involving the transfer of corporate profits. This note explains the operation of s1305A, including examples of how the legislation will apply.
This does not apply to any arrangement falling within section 695A of the Corporation Tax Act 2009 (CTA2009) which came into effect from 5 December 2013 and relates specifically to derivative contracts, but it does apply to any arrangements that are put in place to circumvent that provision.