This part of GOV.UK is being rebuilt – find out what beta means

HMRC internal manual

Corporate Finance Manual

Loan relationships: tax avoidance: commencement

## {#IDAQ54MB}

CTA09/S311 and S312

This guidance applies for accounting periods beginning on or after 6 December 2010. For periods before that date, refer to CFM33120 and CFM33122.


CFM39210 to CFM39230 explain that for periods of account beginning on or after 6 December 2010, the derecognition anti-avoidance legislation operates as a general rule, wherever an amount is not fully recognised, as a result of the company being party to tax avoidance arrangements.

Periods straddling this date are treated as two separate periods of account, so in effect the new rules apply to credits and debits relating to amounts not fully recognised on or after 6 December 2010.

However, CTA09/S312(3)(a) (the rule that denies debits where amounts are required to be fully recognised) only has effect in relation to avoidance arrangements to which the company became party on or after 23 March 2011.

See CFM33120 and CFM33122 for periods beginning before 6 December 2010.