CG44106 - Targeted rules to prevent income to capital converter schemes by companies - tax advantage - choice of commercial options

It will be relevant to draw a comparison in order to consider whether, in the absenceof the tax considerations:

• the transaction giving rise to the advantage would have taken place at all;
• if so, whether the tax advantage would have been of the same amount; and

whether the transaction would have been made under the same terms and conditions.