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HMRC internal manual

International Manual

Arbitrage: legislation and principles - deductions: condition D - meaning of minimal

Condition D - meaning of minimal

The deductions rules apply if and only if all of the four conditions A-D set out in s233(2)-(5) TIOPA 2010.

Condition D in s233(5) TIOA 2010 is that the amount of the tax advantage is more than a minimal amount.

This picks up similar terminology used in other anti-avoidance legislation and is not defined in the statute. HM Revenue and Customs will normally consider the tax advantage arising from a scheme to be minimal if the sum of all the gross UK tax deductions arising from the scheme is less than £50,000.