Rules potentially relevant

Certain rules that apply generally for CT may counter transactions aimed at exploiting the rules in CTA09/PART8 or using those rules for other avoidance purposes.

The provisions are:

the transfer pricing rules in TIOPA10/PART4 (see CIRD47060),

the controlled foreign companies rules in TIOPA10/PART9A (see CIRD47010),

the ‘loss-buying’ rules on the change of ownership of a company (CTA10/PART14/CHAPTER3 AND CHAPTER4), (see CIRD48050),

the value shifting rules in TCGA92/S30 onwards (see CG46800).

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