Introduction Overview Overview Section 373: Other avoidance
1148.This section disapplies sections 360 to 369 where three conditions are met. It is based on section 502GC(1) to (3) and (5) of ICTA.
1149.The three conditions counter arrangements involving a long funding lease which are intended to create tax profits which are substantially less than, or tax losses which are substantially greater than, the profits or losses arising from the arrangements as shown in the lessor company’s accounts. The section may also apply where there is a tax loss and an accounting profit.