Corporation Tax Act 2009 section 1112I

Transactions aimed at obtaining credit or relief to be disregarded

Section 1112I is an anti-avoidance provision that requires certain transactions to be disregarded when they are connected to arrangements whose main purpose is to obtain or inflate relief under this Part of the Act.

• Transactions linked to arrangements entered into for a disqualifying purpose must be disregarded when determining a company's entitlement to relief under this Part
• Arrangements have a disqualifying purpose if one of their main purposes is to enable a company to obtain relief it would not otherwise be entitled to
• Arrangements also have a disqualifying purpose if one of their main purposes is to enable a company to obtain relief of a greater amount than it would otherwise be entitled to
• A transaction only needs to be disregarded to the extent that it is attributable to the disqualifying arrangements, not necessarily in its entirety