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United Kingdom
United Kingdom
Key definition
Anti-avoidance definition What does Anti-avoidance mean? Anti-avoidance describes measures used to stop parties structuring transactions to sidestep statutory liabilities or weaken creditor protections. In pensions practice in the UK, it most often refers to The Pensions Regulator’s (TPR) powers to deter or remedy avoidance of defined benefit scheme obligations, especially the section 75 employer debt. Although “anti-avoidance” is a descriptive term, key powers are set out in legislation. Under the Pensions Act 2004 (as amended, notably by the Pension Schemes Act 2021), TPR may issue: - Contribution notices (CNs), requiring payment to a scheme. Statutory “tests” include main purpose, material detriment, and (from 2021) the...
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UK corporation tax: CTA 2009 ss 441–442 unallowable purpose for loan relationships—scope, purpose attribution (including group), main purpose, apportionment, key cases and HMRC guidance
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Practice notes
Practice Note: Loan relationships—the main tax rules
As discussed in more detail in Practice Note: Loan relationships—the main tax rules, the starting point is that a company brings into account credits and debits (in broad terms, profits and losses) from its loan relationships for corporation tax purposes under the loan relationships regime by reference to its accounting profit and loss, as disclosed in the company’s relevant accounts prepared in accordance with generally accepted accounting practice (GAAP). Put another way, GAAP-compliant accounts provide the framework for identifying whether taxable amounts exist, their measurement, and the timing with which they are recognised for corporation tax in relation to loan relationships. This is often captured by the phrase ‘tax follows the accounts’. The legislative provisions for taxing loan relationships sit chiefly in Part 5 of the Corporation Tax Act 2009 (CTA 2009, ss 292–476), with further provisions in Part 6 (CTA 2009, ss 477–569). There are, however, various cases where the tax treatment of loan relationships departs from a simple reliance on the company’s accounts; a notable example is where the anti-avoidance provisions in Part 5 are triggered...
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Web page updated on 27/05/2026
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Date [ date ] Parties [ name of Landlord ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Landlord) [ name of Tenant ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Tenant) [ [ name of Guarantor ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Guarantor) ] [ [ name of Mortgagee ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Mortgagee) ] Definitions Within this Deed, the terms below shall be interpreted as follows: [ Annual Rent • the annual sum reserved under the Lease; ] [ Insurance Rent • the Tenant’s share of the Landlord’s costs of insuring the Property (as set out in the Lease); ] Lease • the lease of the Property dated [ date ], entered into between (1) [ the Landlord OR [ name ...
I, [ name ], of [ address ], solemnly and sincerely state that: [ Matters to be verified, set out in numbered paragraphs ] I make this solemn statement in good conscience, believing it to be true, and pursuant to the provisions of the Statutory Declarations Act 1835. DECLARED at [ details ] this [ day ] day of [ month and year ] Before me ................................................................................ [ signature of the person before whom the declaration is made ] A [ commissioner for oaths OR [ solicitor OR [ insert other qualification ] ] authorised to administer oaths ]...
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