HMRC published guidance on the interpretation of the para. 4ZA provisions, following their introduction in 2008.

‘Introduction

1 This article gives practical and technical guidance following the introduction of paragraph 4ZA of Schedule 7 to the FA 2003 in Budget 2008.

2 This article also sets out how HMRC will interpret paragraph 4(4) of Schedule 7 to the Finance Act 2003.

3 The guidance provided in this note will apply in normal commercial situations. But where it appears that the guidance is being used for avoidance purposes the circumstances may warrant strict application of the group relief legislation.

Background

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