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HMRC internal manual

International Manual

HM Revenue & Customs
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Arbitrage: legislation and principles - receipts: meaning of scheme for receipts cases

As with the deductions rules, it is necessary that the arrangements giving rise to the arbitrage constitute a scheme. However, whereas it is necessary for the deductions rules that the scheme is a qualifying scheme which includes a hybrid entity or instrument, it is not necessary (for the receipts rules to apply) for the scheme to be a qualifying scheme.