Schedule 4 | Amounts Not Fully Recognised For Accounting Purposes | Finance Act 2011 C11

SCHEDULE 4 Amounts Not Fully Recognised for Accounting Purposes

Finance Act 2011 (2011 c 11) | Legislation

SCHEDULE 4 Amounts Not Fully Recognised for Accounting Purposes

Section 28 Loan relationships

Part 5 of CTA 2009 (loan relationships) is amended as follows.

(1) Section 311 (amounts not fully recognised for accounting purposes) is amended as follows.

(2) In subsection (2)—

(a) at the end of paragraph (a) insert “and”, and

(b) for paragraphs (b) and (c) substitute—

“(b) as a result of tax avoidance arrangements to which the company is at any time a party, an amount is (in accordance with generally accepted accounting practice) not fully recognised for the period in respect of the creditor relationship.”

(3) Omit subsections (3) to (5A).

(4) In subsection (6)—

(a) in the opening words—

(i) after “section” insert “and section 312”, and

(ii) omit “, a contribution to it or securities issued by it”, and

(b) in paragraphs (a) and (b), omit “, contribution or securities”.

(5) After subsection (6) insert—

“(7) For the purposes of this section arrangements are “tax avoidance arrangements” if the main purpose, or one of the main purposes, of any party to the arrangements, in entering into them, is to obtain a tax advantage.

(8) In subsection (7)