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HMRC internal manual

Corporate Finance Manual

Debt cap: anti-avoidance rules: financial services exclusion and anti-avoidance rules

This guidance applies to worldwide group periods of account ending before or straddling 1 April 2017.

The anti-avoidance rules in Chapter 6 do not apply to the financial services exclusion rules

The rules dealing with the financial services exclusion are within TIOPA10/CH2/PT7. However the anti-avoidance rules dealing with manipulation of the rules within Chapter 2 do not cover the financial services exclusion rules in that TIOPA10/S306 only applies to schemes that are intended to secure that a group passes the gateway test.

The risk of a group being able to manipulate the financial services exclusion rules so that a group with no financial services business avoids the application of the debt cap is likely to be small and so there are no particular anti-avoidance rules relating to that exclusion.