This guidance considers how the Profit Fragmentation legislation will apply to adjustments that are within the scope of both Paragraph 7 of the Profit Fragmentation legislation and S731 ITA 2007 of the TOAA legislation.

Benefit Charge

If Profit Fragmentation legislation is applicable to arrangements under which a benefit charge under S731 ITA 2007 is later raised no relief will be available to set against the amount paid under S731 ITA 2007 to take account of the tax paid under the Profit Fragmentation legislation.

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