INTM225850 - Controlled Foreign Companies: Entity Exemptions: Chapter 13 - The Low Profit Margin Exemption: Anti-avoidance
TIOPA10/S371MC provides an anti-avoidance rule to prevent the exemption from applying where an arrangement is entered into which has a main purpose of securing that the exemption applies. The arrangement can have been entered into at any time.
鈥淎rrangement鈥� is widely defined. Further details of what is meant by an arrangement can be found at INTM248100.