Finance Bill (HC Bill 116)

(4) If an accounting period begins before 1 April 2017 and ends on or after that
30date, sub-paragraph (3) is to have effect as if so much of the accounting
period as falls before that date, and so much of that period as falls on or after
that date, were treated as separate accounting periods.

(5) Arrangements are not “relevant avoidance arrangements” for the purposes
of section 461 if the obtaining of any tax advantages that would otherwise
35arise from them can reasonably be regarded as arising wholly from
commercial restructuring arrangements entered into in connection with the
commencement of Part 10 of TIOPA 2010.

(6) For this purpose “commercial restructuring arrangements” means—

(a) arrangements that, but for that Part, would have resulted in
40significantly more corporation tax becoming payable as a result of
one or more loan relationships being brought within the charge to
corporation tax, or

(b) arrangements that—

(i) are designed to secure, in a way that is wholly consistent with
45its policy objectives, the benefit of a relief expressly conferred
by a provision of that Part, and