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HMRC internal manual

Banking Manual

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.