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GB 14: When combination of changes increases loss
or “ Increases in losses from foreign company ownership changes are limited ”
You could also call this:

“Rules for transferring CFC interests and measuring income to prevent tax avoidance”

If you transfer your income interest in a Controlled Foreign Company (CFC) to someone you’re associated with, you need to be careful about how you handle certain elections. These elections are about how often you measure the CFC’s income. You and the person you’re associated with can’t make an arrangement about whether to make or not make these elections if it goes against the spirit of the international tax rules. If you do, the Commissioner of Inland Revenue can step in. They can decide that you did or didn’t make the election, whichever stops your arrangement from having its intended effect. This is to make sure you’re not trying to avoid paying the right amount of tax.

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Next up: GB 15BA: CFC income or loss: arrangements for inclusion of CFC in test group

or “Rules for grouping foreign companies to manage income and losses”
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Part G Avoidance and non-market transactions
Avoidance: specific

GB 15CFC income or loss: arrangements related to quarterly measurement

  1. This section applies when—

  2. an income interest in a CFC is transferred by a person to an associated person; and
    1. the associated persons make an arrangement for making or not making an election under section EX 26(3) (Use of quarterly measurement); and
      1. the arrangement has an effect of defeating the intent and application of the international tax rules.

        1. The Commissioner may treat the election as having been made or not made, as applicable, to the extent appropriate to prevent the effect of the arrangement.

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