292-255 Disposals of income streams: corporation tax provisions
The provisions apply where a company (the ‘transferor’) disposes of a right to relevant receipts to another person (the ‘transferee’) by or through a partnership (the relevant partnership) and the company and the transferee are members of the relevant partnership, or are members of partnerships associated with the relevant partnership. Where obtaining a tax advantage is a main purpose of any step of the arrangements directly or indirectly involving the disposal, the relevant amount is chargeable to corporation tax in the hands of the transferor (CTA 2010, s. 757A(1)).
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