Paragraph 17 Related amounts
United Kingdom
For the purposes of the threshold test in paragraph 11(2), two uncertain amounts are related if—
both amounts are included in the same relevant return, or a relevant return of the same description delivered to HMRC for the same financial year,
both amounts relate to the same relevant tax, and
the tax treatment applied in arriving at one amount is substantially the same as the tax treatment applied in arriving at the other amount.
Where the relevant return is a return under PAYE regulations, national insurance contributions are to be treated as income tax for the purposes of this paragraph (and accordingly, for the purposes of determining the aggregate value of the tax advantages mentioned in paragraph 11(2)(b)).