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HMRC internal manual

Orchestra Tax Relief

Orchestra Tax Relief: Avoidance: Tax avoidance arrangements

S1217RL Corporation Tax Act 2009

The orchestra tax regime includes a targeted anti-avoidance provision (TAAR) designed to prevent contrived arrangements aimed at inflating the amount of Orchestra Tax Relief (OTR) to which an Orchestral Production Company (OPC) is entitled.

Its effect is to exclude any transaction undertaken with the aim of inflating the relief.

A company will not qualify for relief where the main or one of the main purposes of the arrangements is to claim the Orchestra Tax Credit (OTC) or otherwise benefit from the relief to obtain a tax advantage such as gaining OTR that would not otherwise be available. This may include increasing the amount of additional deduction or Orchestra Tax Credit beyond what was otherwise available.

The meaning of ‘tax advantage’ is given by Section 1139 of Corporation Tax Act 2010.