Policy paper

Anti-avoidance rule relating to certain non-derecognition liabilities

This measure is about introducing an anti-avoidance provision relating to certain non-derecognition liabilities.

Documents

Draft legislation

Request an accessible format.
If you use assistive technology (such as a screen reader) and need a version of this document in a more accessible format, please email different.format@hmrc.gov.uk. Please tell us what format you need. It will help us if you say what assistive technology you use.

Explanatory note

Request an accessible format.
If you use assistive technology (such as a screen reader) and need a version of this document in a more accessible format, please email different.format@hmrc.gov.uk. Please tell us what format you need. It will help us if you say what assistive technology you use.

Details

This measure introduces a new anti-avoidance provision relating to certain arrangements where there is a non-derecognition liability. 
 
This measure will take effect from 26 November 2025.

Updates to this page

Published 26 November 2025

Sign up for emails or print this page