F1PART 3AGENERAL ANTI-AVOIDANCE RULE
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.
Pt. 3A inserted (1.4.2018) by Land Transaction Tax and Anti-avoidance of Devolved Taxes (Wales) Act 2017 (anaw 1), ss. 66, 81(2)(3); S.I. 2018/34, art. 3