Section 16

INTRODUCTION AND OVERVIEW

Related Commentary  

1(1)  This Schedule contains provision about countering the tax effects of certain arrangements (“profit fragmentation arrangements”).

1(2)  Profit fragmentation arrangements involve the following parties–

(a)a person resident in the United Kingdom (“the resident party”),

(b)an overseas person or entity (“the overseas party”) who is not resident in the United Kingdom, and

(c)an individual (a “related individual”) who is–

(i)the resident party,

(ii)a member of a partnership of which the resident party is a partner, or

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