CAA01/s33A,S33B; FA08/Sch 26, paragraphs 15-17

Anti-avoidance provision: sale between connected persons

FA08 introduced an anti-avoidance provision to prevent connected persons from entering into transactions, simply with a view to obtaining WDAs on historic expenditure on assets, which are now defined as ‘integral features’, but which did not qualify for any WDAs when the current owner acquired the assets.

For example, most cold water and electrical systems in commercial offices did not qualify for any PMAs or WDAs before the integral features provisions in CAA01/S33A were introduced.

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