Introduction Equity holders Overview Section 127: Amounts excluded because of certain arrangements
474.This section is a rule to deal with contrived situations. It is based on section 403G of ICTA.
475.Subsection (1) excludes from the EEA amount any amount that arises from an “arrangement”. The exclusion is mentioned in Step 5 of section 113(2). Subsection (1)(a) of the section ensures that the rule does not apply to any part of the EEA amount that is attributable to a United Kingdom permanent establishment. That part is dealt with under section 107.
476.Subsection (2) identifies the excluded amount by reference to “arrangements”.
477.Subsection (3) tests the purpose of the arrangements. They are within this section if their main purpose is to secure group relief.