BLM82035 - Sale of lessor companies and similar arrangements: anti- avoidance: manipulation of balance sheet values – main purpose test


FA06/SCH10/PARA38A cancels the effect of arrangements which prevent Schedule 10 from operating as intended. It applies to a change of ownership that happens on or after 22 November 2006.

The paragraph applies:

  • whenever there is an increase or a decrease in the amount that is shown in the balance sheet of a company; and
  • that increase or decrease is caused because the company has directly or indirectly entered into arrangements, see BLM82040; and
  • the main purpose, or one of the main purposes, of the arrangements is to secure a tax advantage, see BLM82045.