Related Commentary  Related HMRC Manuals

12(1)  A disposition made by any person is not a transfer of value if it is allowable in computing that person’s profits or gains for the purposes of income tax or corporation tax or would be so allowable if those profits or gains were sufficient and fell to be so computed.

12(2)  Without prejudice to subsection (1) above, a disposition made by any person is not a transfer of value if it is a contribution under a registered pension scheme, a qualifying non-UK pension scheme or a section 615(3) scheme in respect of an employee of the person making the disposition.

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