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.