Related Commentary  Related HMRC Manuals

31(1)  Any relevant permissive rule in this Part–

(a)has priority over any relevant prohibitive rule in this Part, but

(b)is subject to section 36 (unpaid remuneration), section 38 (employee benefit contributions), section 48 (car hire) and section 55 (crime-related payments).

31(1A)  But, if the relevant permissive rule would allow a deduction in calculating the profits of a trade in respect of an amount which arises directly or indirectly in consequence of, or otherwise in connection with, relevant tax avoidance arrangements, that rule–

(a)does not have priority under subsection (1)(a), and

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