Introduction Overview Overview Section 799: Manufactured payments under arrangements with unallowable purpose
2395.This section denies tax relief for manufactured payments made under arrangements having an unallowable purpose. It is based on paragraph 7A of Schedule 23A to ICTA.
2396.Subsection (1) states when the section applies.
2397.Subsection (2) sets out the consequences of the section applying.
2398.Subsection (3) defines “relevant tax relief”.
2399.Subsections (4) and (5) state when a company is subject to another relevant tax relief restriction for the purposes of this section. See the priority rule in subsection (1)(d).
2400.Subsection (6) requires the manufactured payment to be justly and reasonably apportioned in order to determine the part which is attributable to the unallowable purpose.
2401.Subsection (7) is a signpost to the definition of “arrangements” in section 801 of this Act.