Commentary on Sections Overview Overview Section 306: Schemes involving manipulation of rules in Chapter 2
589.This section counters schemes that attempt to manipulate the “gateway” conditions. For example, a group that would otherwise fail the test in section 261 (so that the debt cap rules applied) might borrow from a bank at the end of its period of account to boost the “worldwide gross debt” amount defined in section 264, repaying the loan the next day. The section is based on paragraph 47 of Schedule 15 to FA 2009.