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<p>There have been a large number of measures over the years which operate to counter
Corporation Tax avoidance using intra-group loans and derivatives. The key measures
are the ‘unallowable purpose’ rules (sections 441 and 690 of Corporation Tax Act 2009),
the transfer pricing rules (Part 4 of Taxation (International and Other Provisions)
Act 2010 (“TIOPA 2010”)), the group mismatch scheme rules (Part 21B of Corporation
Tax Act 2010 (“CTA 2010”)), the tax mismatch scheme rules (Part 21BA of CTA 2010),
the hybrid and other mismatches rules (Part 6A of TIOPA 2010), the controlled foreign
companies rules (Part 9A of TIOPA 2010) and the corporate interest restriction rules
(Part 10 of TIOPA 2010). Taken together these measures have been successful in protecting
revenues, but it is not possible to say how much would otherwise have been lost.</p>
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