Corporation Tax Act 2009

1205Artificially inflated claims for additional deduction or film tax creditU.K.

(1)So far as a transaction is attributable to arrangements entered into wholly or mainly for a disqualifying purpose, it is to be ignored in determining for any period—

(a)any additional deduction which a company may make under this Chapter, and

(b)any film tax credit to be given to a company.

(2)Arrangements are entered into wholly or mainly for a disqualifying purpose if their main object, or one of their main objects, is to enable a company to obtain—

(a)an additional deduction under this Chapter to which it would not otherwise be entitled or of a greater amount than that to which it would otherwise be entitled, or

(b)a film tax credit to which it would not otherwise be entitled or of a greater amount than that to which it would otherwise be entitled.

(3)“Arrangements” includes any scheme, agreement or understanding, whether or not legally enforceable.