817A Restriction of relief for payments of interest

This section provides that interest will not qualify for tax relief under Part 8 if a scheme has been put in place and the sole or main benefit of the scheme is to obtain a reduction in tax liability. It goes on to provide that, in determining the benefits which arise from the scheme, account is to be taken of any surrender of tax relief to a fellow-group company of the borrowing company under the group relief provisions.

Relevant Date: Finance Act 2019