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HMRC internal manual

Company Taxation Manual

Corporation Tax: management expenses: targeted anti-avoidance rule (TAAR) - outlying provisions

Various provisions of the Taxes Acts deem or treat particular expenses as expenses of management. Where amounts are simply deemed to be or are treated as expenses of management within CTA09/S1219(1) then the remaining provisions of CTA09/Part 16 (e.g. capital exclusion), including, Section 1248 automatically apply to the expenditure.

Other provisions of the Taxes Acts state that certain expenditure is deductible as expenses of management. CTA09/S1248(4) ensures that these expenses are also subject to the TAAR.

Certain Manufactured Payments are deemed to be expenses of management by CTA10/S791. CTA10/S799 contains its own unallowable purpose rule. CTA09/S1248(3) ensures that that specific unallowable purpose continues to apply in priority to Section 1248. That is not to say that Section 1248 cannot apply, it will only apply in appropriate circumstances where CTA10/S799 does not. CTA09S1219(2) and S1220 do however have priority over CTA10/S799, so the order is Section 1219(2)  then CTA10/S799 and then if necessary CTA09/S1248.