On 21 December 2012, the Government announced legislation for inclusion in the 2013 Finance Bill that will introduce targeted anti-avoidance rules (TAARs) to (i) sections 31 and 274 of The Income Tax (Trading and Other Income) Act 2005 and (ii) sections 51 and 214 of the Corporation Tax Act 2009, which govern the relationship between rules prohibiting and allowing deductions.

Currently, thes…