Section 1248 — Corporation Tax Act 2009: Expenses in connection with arrangements for securing a tax advantage

Expenses in connection with arrangements for securing a tax advantage 1248 1 No deduction is allowed under section 1219 for any particular expenses of management if any part of those expenses is incurred directly or indirectly in consequence of, or otherwise in connection with, any arrangements for securing a tax advantage.

2 In subsection (1) “ arrangements for securing a tax advantage ” means arrangements the main purpose, or one of the main purposes, of which is to secure—

a the allowance of a deduction (or increased deduction) under section 1219, or b any other tax advantage. 3 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

4 The reference in subsection (1) to expenses of management includes amounts treated by any provision as deductible under section 1219.

5 In this section— “ arrangements ” includes any agreement, understanding, scheme, transaction or series of transactions (whether or not legally enforceable), ... “ tax advantage ” has the meaning given by section 1139 of CTA 2010 .