Tax anti-avoidance rules

This Overview provides an introduction to the UK’s rules for countering arrangements to avoid tax. These rules are predominantly in legislation, but there is also a body of case law (the Ramsay principle, and its indirect tax equivalent, the abuse of rights or Halifax principle) that may be used by the courts to deprive tax avoidance arrangements of their intended effect.

This Overview is about rules for countering tax avoidance in general, as opposed to the more targeted anti-avoidance rules (sometimes abbreviated to TAARs) that exist in specific areas of the tax legislation. Examples of these more targeted rules are those affecting transactions in securities, the loan relationships unallowable purposes rule, and the capital gains value shifting provisions. Information on these targeted rules, some of which have clearance procedures under which taxpayers can apply to HMRC for confirmation that the rules will not apply to them, is included as part of the guidance on the relevant areas of tax legislation.

This Overview is focused on business taxes. For an equivalent Overview designed for Private Client practitioners, see: General principles of tax avoidance—Private Client—overview.

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