F1PART 3AGENERAL ANTI-AVOIDANCE RULE

Annotations:

Artificial tax avoidance arrangements

81BTax avoidance arrangements

1

For the purposes of this Part, an arrangement is a ““tax avoidance arrangement”” if the obtaining of a tax advantage for any person is the main purpose, or one of the main purposes, of a taxpayer entering into the arrangement.

2

In determining whether the main purpose, or one of the main purposes, of an arrangement is the obtaining of a tax advantage regard may in particular be had to the amount of devolved tax that would have been chargeable in the absence of the arrangement.

3

In this Part—

a

an “"arrangement”” includes any transaction, scheme, action, operation, agreement, grant, understanding, promise, undertaking, event or any series of any of those things (whether legally enforceable or not);

b

references to an arrangement are to be read as including—

i

a series of arrangements, and

ii

any part or stage of an arrangement comprised of more than one part or stage;

c

"taxpayer”” means a person liable to devolved tax or who would be liable but for the tax avoidance arrangement in question.