{
  "url": "https://openlegislation.uk/finance-act-2013/schedule-26/paragraph-3",
  "json_url": "https://openlegislation.uk/finance-act-2013/schedule-26/paragraph-3.json",
  "legislation": "ukpga/2013/29",
  "legislation_title": "Finance Act 2013",
  "legislation_url": "https://openlegislation.uk/finance-act-2013",
  "path": "schedule/26/paragraph/3",
  "kind": "paragraph",
  "number": "3",
  "heading": null,
  "text": "After section 212L insert—\n“Limiting conditions\nLimiting conditions\n212LA (1) The qualifying change meets one of the limiting conditions if condition A, B, C or D is met.\n(2) Condition A is that the amount of the relevant excess of allowances is £50 million or more.\n(3) Condition B is that the amount of the relevant excess of allowances—\n(a) is £2 million or more but less than £50 million, and\n(b) is not insignificant as a proportion of the total amount or value of the benefits derived by any relevant person by virtue of the qualifying change or change arrangements.\n(4) “Relevant person” means a person who, at the end of the relevant day, is—\n(a) a principal company of C,\n(b) a person carrying on the relevant activity in partnership, or\n(c) a person who is connected to a person within paragraph (a) or (b) (within the meaning of section 1122 of CTA 2010).\n(5) Condition C is that—\n(a) the amount of the relevant excess of allowances is less than £2 million, and\n(b) the qualifying change has an unallowable purpose.\nSee section 212M for the meaning of “unallowable purpose”.\n(6) Condition D is that the main purpose, or one of the main purposes, of any arrangements is to procure that condition A or B or paragraph (a) of condition C is not met.\n(7) In this section—\nthe amount of the relevant excess of allowances is the difference between RTWDV and BSV (see sections 212K and 212L);\n“change arrangements” and “arrangements” have the same meaning as in section 212M.”",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2013/29/schedule/26/paragraph/3",
    "retrieved_at": "2026-10-29T09:08:06.076240+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}