Introduction Summary
1.Section 42 introduces Schedule 20 which responds to tax avoidance schemes involving a tax mismatch. Tax mismatch schemes exploit the tax treatment of loan relationships and derivative contracts in the Corporation Tax Acts 2009 and 2010. The amendments block schemes where a company benefits from a tax advantage by creating a mismatch using a loan relationship or derivative. The changes apply, although they are not limited to, schemes where a company enters a loan relationship with a partnership of which it is a member and a loan is accounted for differently by the company and the partnership to give a tax advantage.