As would be expected there are wide ranging, broadly drafted anti-avoidance provisions as detailed below.
Artificial arrangements
Companies or groups of companies are prevented from entering into artificially manipulated commercial arrangements ('prescribed arrangements') in order to meet the ongoing tests and conditions of the REIT regime in relation to the conditions for the tax-exempt business (D7.1105) and the conditions for the balance of business (D7.1106)1. These rules apply to arrangements entered into by a company or group of companies on or after 7 May 2009 (and during an accounting period which ends on or after 15 December 2009)2, unless they are genuine commercial arrangements or between persons dealing at arm's length3.
The
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