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HMRC internal manual

Corporate Finance Manual

Derivative contracts: tax avoidance: overview of anti-avoidance rules

CFM56000+ follows the Tax Avoidance chapter at CTA09/PT7/CH11 and therefore contains guidance on rules about:

  • Unallowable purposes (CFM56010);
  • Interaction with transfer pricing rules (CFM56050);
  • Transfers of value to connected companies (CFM56070);
  • Transactions with non-UK residents (CFM56090);
  • Disposals for consideration not fully recognition by accounting practice (CFM56100).

It also deals with guidance on amounts not fully recognised for accounting purposes (CTA09/S599A and S599B as well as S698A) (CFM56110).

Apart from these rules there are a number of other rules intended to address potential avoidance:

  • Anti-avoidance provisions within the group continuity rules (CFM53100+);
  • Group mismatch scheme rules (CFM77500+).

Note that guidance on anti-avoidance provisions to do with forex is at CFM63000+ and loan relationships is at CFM38000+.