This section applies for the purposes of corporation tax in respect of chargeable gains if conditions A to D are satisfied.
Condition A is that—
Condition B is that the relevant company, or a company connected with the relevant company, becomes entitled to an income deduction directly or indirectly in consequence of, or otherwise in connection with, the arrangements.
Condition C is that the main purpose, or one of the main purposes, of the arrangements is to secure a tax advantage that involves both—
whether or not it also involves anything else.
Condition D is that the arrangements are not excluded arrangements. For this purpose arrangements are excluded arrangements if—
If the Board consider, on reasonable grounds, that conditions A to D are or may be satisfied, they may give the company a notice in respect of the arrangements (but see also section 184I).
If, when the notice is given, conditions A to D are satisfied, no loss accruing to the company at any time is to be deductible from the relevant gain.
A notice under this section must—
If relevant gains accrue in more than one accounting period, a single notice under this section may specify all the accounting periods concerned.
In this section—
"arrangements" includes any agreement, understanding, scheme, transaction or series of transactions (whether or not legally enforceable),
"income deduction" means—
(a)a deduction in calculating income for corporation tax purposes, or
(b)a deduction from total profits,
"tax advantage" has the meaning given by section 184D.
For the purposes of this section it does not matter whether the tax advantage is secured for the relevant company or for any other company.