An anti-avoidance rule in relation to the exempt period exemption is set out at TIOPA10/S371JF. The exempt period exemption will not apply if either condition A or B is met.

Condition A

TIOPA10/S371JF(2) sets out Condition A, which is that an arrangement:

(1)is entered into which has a main purpose of securing a tax advantage for any person,

(2)is linked to the potential application of the exemption for one or more accounting periods, and

(3)involves the CFC either holding assets which give rise to finance profits, or holding intellectual property which gives rise to income.

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