19 Losses: counteraction of avoidance arrangements
Finance (No 2) Act 2017 (2017 c 32) | Legislation

19  Losses: counteraction of avoidance arrangements

(1)     Any loss-related tax advantage that would (in the absence of this section) arise from relevant tax arrangements is to be counteracted by the making of such adjustments as are just and reasonable.

(2)     Any adjustments required to be made under this section (whether or not by an officer of Revenue and Customs) may be made by way of—

(a)     an assessment,

(b)     the modification of an assessment,

(c)     amendment or disallowance of a claim,

or otherwise.

(3)     For the purposes of this section arrangements are “relevant tax arrangements” if conditions A and B are met.

(4)     Condition A is that the purpose, or one of the main purposes, of the arrangements is to obtain a loss-related tax advantage.

(5)     Condition B is that it is reasonable to regard the arrangements as circumventing the intended limits of relief under the relevant

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