{
  "url": "https://openlegislation.uk/finance-no-2-act-2017/schedule-16/paragraph-6",
  "json_url": "https://openlegislation.uk/finance-no-2-act-2017/schedule-16/paragraph-6.json",
  "legislation": "ukpga/2017/32",
  "legislation_title": "Finance (No. 2) Act 2017",
  "legislation_url": "https://openlegislation.uk/finance-no-2-act-2017",
  "path": "schedule/16/paragraph/6",
  "kind": "paragraph",
  "number": "6",
  "heading": null,
  "text": "(1) Condition B is that (in a case not falling within Condition A)—\n(a) HMRC have made an assessment in relation to tax,\n(b) the assessment counteracts a tax advantage that it is reasonable to assume T expected to obtain from the arrangements concerned (“the expected tax advantage”), and\n(c) the counteraction is final.\n(2) For the purposes of this paragraph an assessment “counteracts” the expected tax advantage if the assessment is on a basis which prevents T from obtaining (or obtaining the whole of) the expected tax advantage.\n(3) For the purposes of this paragraph a counteraction is “final”—\n(a) when a relevant contract settlement is made, or\n(b) if no contract settlement has been made, when the assessment in question and any amounts arising from the assessment can no longer be varied, on appeal or otherwise.\n(4) In sub-paragraph (3) a “relevant contract settlement” means a contract settlement on a basis which prevents T from obtaining (or obtaining the whole of) the expected tax advantage.",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2017/32/schedule/16/paragraph/6",
    "retrieved_at": "2026-10-29T09:05:16.335265+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."
}