Bank loss restriction: targeted anti-avoidance rule: situations where the TAAR would not apply
HM Revenue & Customs would not consider the anti-avoidance rules to apply in the following situations:
- The arrangement does not create a tax advantage overall to the UK group
- The only reduction in tax is due to the claim and surrender of group relief between the two parties
- The value of the tax advantage is less than 50 percent of the net overall value to the group of entering into the arrangement.