# Taxation (International and Other Provisions) Act 2010, Section 371SP: Disguised interest: application of Chapter 2A of Part 6 of CTA 2009


(1) This section applies if—
(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
(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.
(2) Chapter 2A of Part 6 of CTA 2009 is to be assumed to apply in relation to the return.
(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.
(4) This section is without prejudice to the generality of section 371SO.

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Source: https://www.legislation.gov.uk/ukpga/2010/8/section/371SP (the official version)
Page: https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/section-371SP
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.

