{
  "url": "https://openlegislation.uk/income-and-corporation-taxes-act-1988/schedule-28AB/paragraph-6",
  "json_url": "https://openlegislation.uk/income-and-corporation-taxes-act-1988/schedule-28AB/paragraph-6.json",
  "legislation": "ukpga/1988/1",
  "legislation_title": "Income and Corporation Taxes Act 1988",
  "legislation_url": "https://openlegislation.uk/income-and-corporation-taxes-act-1988",
  "path": "schedule/28AB/paragraph/6",
  "kind": "paragraph",
  "number": "6",
  "heading": null,
  "text": "(1) This paragraph applies to a scheme or arrangement if the scheme or arrangement includes—\n(a) the making by a person (“A”) of a relevant payment or payments, and\n(b) the giving, in respect of that payment or payments, of consideration that satisfies the requirements of sub-paragraph (3).\n(2) A payment made by A is a relevant payment if all or part of it may be brought into account in computing A's income for the purposes of United Kingdom taxes.\n(3) Consideration given in respect of a payment or payments made by A satisfies the requirements of this sub-paragraph if—\n(a) all or part of it consists of a payment or payments made to A or a person connected with A, and\n(b) tax is chargeable in respect of the payment or payments under the law of a territory outside the United Kingdom.\n(4) In this paragraph references to a payment include references to a transfer of money's worth.\n(5) Section 839 applies for the purposes of this paragraph.",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/1988/1/schedule/28AB/paragraph/6",
    "retrieved_at": "2026-10-29T09:49:54.309394+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."
}