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HMRC internal manual

Capital Gains Manual

Targeted rules to prevent income to capital converter schemes by companies - definition of tax advantage

“Tax advantage” has the meaning given in TCGA92/S184D. There are four legs tothis definition, which cover relief, repayments, the amount of a charge, and theassessment of corporation tax.

If a tax advantage arises out of a transaction that is part of the arrangements, thelegislation asks whether the main purpose or one of the main purposes of the arrangements(referred to as “a main purpose” in this guidance) is to achieve a taxadvantage. The purpose of the arrangements is determined by the purpose of theparticipants in entering into the arrangements. If any participant has a main purpose ofachieving a tax advantage, that will constitute a main purpose of the arrangements.