INTM598000 - Arbitrage: practical guidance - examples demonstrating the application of the arbitrage legislation - Contents

The following examples are intended to assist companies in deciding whether their arrangements might fall within the avoidance through arbitrage rules. The examples are illustrative and are not meant to be exhaustive. Thus the absence of a particular structure or arrangement does not imply it is or is not covered by the legislation.

Additional examples will be added if points of general application arise that are not already covered, in the light of HM Revenue & Customs’ experience of applying the legislation in practice.

For most of these examples the alternate treatment is referred to as Code A. This could be the tax code of a different country or it could be a different UK code to that shown as ‘UK view’.

1. INTM598010

   Example 1 Part 1 - inward investment
2. INTM598020

   Example 1 Part 2 - inward investment
3. INTM598030

   Example 1 Part 3 - inward investment
4. INTM598040

   Example 2 Part 1 - outward investment
5. INTM598050

   Example 2 Part 2 - outward investment
6. INTM598060

   Example 2 Part 3 - outward investment
7. INTM598070

   Example 2 Part 4 - outward investment
8. INTM598080

   Example 3 Part 1 - subordinated debt
9. INTM598090

   Example 3 Part 2 - subordinated debt
10. INTM598100

    Example 4 Part 1 - debt restructuring
11. INTM598110

    Example 4 Part 2 - debt restructuring
12. INTM598120

    Example 5 Part 1 - dividends
13. INTM598130

    Example 5 Part 2 - dividends
14. INTM598140

    Example 6 - receipts legislation - deferred subscription
15. INTM598150

    Example 7 - Controlled Foreign Company restructuring
16. INTM598160

    Example 8 - convertible securities
17. INTM598170

    Example 9 - hybrid entity definition