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HMRC internal manual

Corporate Finance Manual

From
HM Revenue & Customs
Updated
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Anti-avoidance rules - contents

  1. CFM92610
    Debt cap: anti-avoidance rules: introduction
  2. CFM92615
    Debt cap: anti-avoidance rules: general: definition of a scheme
  3. CFM92620
    Debt cap: anti-avoidance rules: general: scheme as part of a wider scheme
  4. CFM92625
    Debt cap: anti-avoidance rules: general: schemes in place before commencement date
  5. CFM92630
    Debt cap: anti-avoidance rules: general: main purpose test
  6. CFM92635
    Debt cap: anti-avoidance rules: general: UK company is not party to particular transactions
  7. CFM92640
    Debt cap: anti-avoidance rules: general: when the purpose test is applied
  8. CFM92645
    Debt cap: anti-avoidance rules: general: change in purpose and whether there is a new scheme to consider
  9. CFM92650
    Debt cap: anti-avoidance rules: general: excluded schemes
  10. CFM92655
    Debt cap: anti-avoidance rules: general: requests for clearances
  11. CFM92660
    Debt cap: anti-avoidance rules: gateway: conditions for anti-avoidance rules to apply
  12. CFM92665
    Debt cap: anti-avoidance rules: gateway: effect of anti-avoidance rules applying
  13. CFM92670
    Debt cap: anti-avoidance rules: gateway: excluded schemes
  14. CFM92675
    Debt cap: anti-avoidance rules: gateway: examples of particular avoidance
  15. CFM92680
    Debt cap: anti-avoidance rules: gateway: non-abusive schemes
  16. CFM92685
    Debt cap: anti-avoidance rules: financial services exclusion and anti-avoidance rules
  17. CFM92690
    Debt cap: anti-avoidance rules: main rules: scope for avoidance
  18. CFM92695
    Debt cap: anti-avoidance rules: main rules: conditions for anti-avoidance rules to apply
  19. CFM92700
    Debt cap: anti-avoidance rules: main rules: meaning of ‘relevant net deduction’
  20. CFM92705
    Debt cap: anti-avoidance rules: main rules: comparing net relevant deductions: examples
  21. CFM92710
    Debt cap: anti-avoidance rules: main rules: Condition B - sum of profits of UK companies
  22. CFM92715
    Debt cap: anti-avoidance rules: main rules: Condition B - losses of UK companies
  23. CFM92720
    Debt cap: anti-avoidance rules: main rules: effect of anti-avoidance rules applying
  24. CFM92725
    Debt cap: anti-avoidance rules: main rules: calculating the counterfactual
  25. CFM92730
    Debt cap: anti-avoidance rules: main rules: calculating the counter factual: examples
  26. CFM92735
    Debt cap: anti-avoidance rules: main rules: excluded schemes: general
  27. CFM92738
    Debt Cap: anti-avoidance rules: main rules: excluded schemes: de minimis amount
  28. CFM92740
    Debt cap: anti-avoidance rules: main rules: particular avoidance: examples
  29. CFM92745
    Debt cap: anti-avoidance rules: main rules: non-abusive schemes: examples
  30. CFM92750
    Debt cap: anti-avoidance rules: EEA financing income: conditions for anti-avoidance rules to apply
  31. CFM92755
    Debt cap: anti-avoidance rules: EEA financing income: effect of anti-avoidance rules applying
  32. CFM92760
    Debt cap: anti-avoidance rules: EEA financing income: excluded schemes
  33. CFM92765
    Debt cap: anti-avoidance rules: EEA financing income: particular avoidance: examples
  34. CFM92770
    Debt cap: anti-avoidance rules: EEA financing income: non-abusive schemes: examples