TTR80030 - Avoidance: tax avoidance arrangements
S1217LA Corporation Tax Act 2009
皇冠体育app theatre tax regime includes a targeted anti-avoidance provision (TAAR) designed to prevent contrived arrangements aimed at inflating the amount of 皇冠体育appatre Tax Relief (TTR) to which a 皇冠体育appatre Production Company (TPC) is entitled.
Its effect is to exclude any transaction undertaken with the aim of inflating the relief.
A company will not qualify for relief where the main or one of the main purposes of the arrangements is to claim the 皇冠体育appatre Tax Credit (TTC) or otherwise benefit from the relief to obtain a tax advantage such as gaining TTR that would not otherwise be available. This may include increasing the amount of additional deduction or 皇冠体育appatre Tax Credit beyond what was otherwise available.
皇冠体育app meaning of 鈥榯ax advantage鈥� is given by Section 1139 of Corporation Tax Act 2010.
Example
A TPC hires an actor for 拢100k, but draws up a contract in which the total fee payable is set at 拢150k. 皇冠体育app actor agrees to reinvest 拢50k in the production in the form of a non-recourse loan to the TPC.
皇冠体育app TPC has no obligation to repay the loan from the actor and so this aspect of the contract has no commercial basis. Instead, the whole purpose of that part of the transaction was to gain an amount of TTR which would not otherwise be available. 皇冠体育apprefore, 拢50k of the contracted fee should be disregarded when calculating the amount of TTR to which the TPC is entitled.