Where ‘tax avoidance arrangements’ (as defined in
CIRD48110) are identified they need to
be disregarded in determining the relevant debits and credits. This
may involve an exercise in identifying the precise transactions etc
involving avoidance in the arrangements under review in the light
of the full facts.
For example, in the first case described in
CIRD48140 (depression of carrying cost
of purchased asset) it may be appropriate to compute the debits and
credits excluding the overcharge for the services provided by the
related company. And in the third case (use of intermediary to turn
existing asset into one within Schedule 29) it may be appropriate
to assume that the asset was transferred directly to the company
from the related party.
