Revenue Note for Guidance
This section is an anti-avoidance section. It provides that relief under the Chapter will only apply to interest and royalty payments made for bona fide commercial reasons and which do not form part of any arrangement or scheme the purpose of which is the avoidance of tax.
(1) The relief provided by the Chapter will only apply to interest and royalty payments made for bona fide commercial reasons and which do not form part of any arrangement or scheme the purpose of which is the avoidance of tax.
(2) If the requirements for exemption cease to be fulfilled, the receiving company is obliged to inform the paying company.
Relevant Date: Finance Act 2019