As might be expected within such complex anti-avoidance provisions there is also a general catch all anti-avoidance rule. This provides that any person who is within the charge to corporation tax (or who would be but for the avoidance) and obtains a relevant tax advantage as a result of relevant avoidance arrangements will have the relevant tax advantage counteracted by the making of just and reasonable adjustments to their corporation tax treatment1. The two key concepts are:
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•ÌýÌýÌýÌý a relevant tax advantage – this is obtained if a person avoids the restriction of a deduction or the imposition of income under the general hybrid and other mismatch rules or an equivalent overseas provision or, in relation to payments made on or after 10 June 2021 or quasi-payments in relation to
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