66 General anti-avoidance rule

Part 7 General Anti-Avoidance Rule

66  General anti-avoidance rule

After section 81 of TCMA (contract settlements), insert—

“Part 3A
General Anti-Avoidance Rule
Overview
81A Meaning of “general anti-avoidance rule” and overview

(1)     This Part makes provision for counteracting tax advantages arising from artificial tax avoidance arrangements, including provision—

(a)     about the meaning of “tax avoidance arrangement”, “artificial” and “tax advantage” (sections 81B to 81D);

(b)     about WRA's power to make adjustments to counteract tax advantages and the steps to be taken by WRA in connection with such adjustments (sections 81E to 81G).

(2)     The rules in this Part are collectively to be known as “the general anti-avoidance rule”.

Artificial tax avoidance arrangements
81B Tax avoidance arrangements

(1)     For the purposes of this Part, an arrangement is a “tax avoidance arrangement” if the obtaining of a tax advantage for any person is the main purpose, or one of the main purposes, of a taxpayer entering into the arrangement.

(2)     In determining whether the main purpose, or one of the main purposes, of an arrangement is the obtaining of a tax advantage regard may in particular be had to the amount of devolved tax that would have been chargeable in the

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