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HMRC internal manual

International Manual

Arbitrage: practical guidance - examples demonstrating the application of the arbitrage legislation - Contents

The following examples are intended to assist companies in deciding whether their arrangements might fall within the avoidance through arbitrage rules. The examples are illustrative and are not meant to be exhaustive. Thus the absence of a particular structure or arrangement does not imply it is or is not covered by the legislation.

Additional examples will be added if points of general application arise that are not already covered, in the light of HM Revenue & Customs’ experience of applying the legislation in practice.

For most of these examples the alternate treatment is referred to as Code A. This could be the tax code of a different country or it could be a different UK code to that shown as ‘UK view’.