{
  "url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/section-371SP",
  "json_url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/section-371SP.json",
  "legislation": "ukpga/2010/8",
  "legislation_title": "Taxation (International and Other Provisions) Act 2010",
  "legislation_url": "https://openlegislation.uk/taxation-international-and-other-provisions-act-2010",
  "path": "section/371SP",
  "kind": "section",
  "number": "371SP",
  "heading": "Disguised interest: application of Chapter 2A of Part 6 of CTA 2009",
  "text": "(1) This section applies if—\n(a) applying the corporation tax assumptions apart from this section, Chapter 2A of Part 6 of CTA 2009 (disguised interest) would, but for section 486D(1) of that Act, apply in relation to a return produced for the CFC by an arrangement to which the CFC is a party, and\n(b) it is reasonable to assume that the main purpose, or one of the main purposes, of the CFC being a party to the arrangement is to obtain a tax advantage within section 1139(2)(da) of CTA 2010 for any person by obtaining what would, applying the corporation tax assumptions apart from this section, be a relevant tax advantage in relation to the CFC.\n(2) Chapter 2A of Part 6 of CTA 2009 is to be assumed to apply in relation to the return.\n(3) In subsection (1)(b) the reference to obtaining what would be a relevant tax advantage is to be read in accordance with section 486D(4) of CTA 2009.\n(4) This section is without prejudice to the generality of section 371SO.",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Pt. 9A inserted (17.7.2012) by Finance Act 2012 (c. 14), Sch. 20 para. 1 (with ss. 56-58)"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2010/8/section/371SP",
    "retrieved_at": "2026-10-29T09:10:17.008829+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."
}