SCHEDULES
SCHEDULE 15Oil activities: transferable tax history
PART 14Supplementary
95Anti-avoidance
1
If a person enters into arrangements within sub-paragraph (2), an officer of Revenue and Customs may—
a
amend a TTH election, or
b
amend or disallow a claim,
to secure that the election or claim has effect as if the arrangements had not been entered into.
2
Arrangements are within this sub-paragraph if it is reasonable to regard the arrangements as—
a
designed to secure that an entitlement to a repayment, or an increased repayment, of tax by reason of the application of any provision of this Schedule, arises earlier than would (apart from the arrangements) be the case,
b
circumventing the intended limits of the provisions of this Schedule on an amount that is relevant for the purposes of determining a repayment of tax by reference to those provisions, or
c
otherwise exploiting shortcomings in those provisions.
3
In this paragraph, “arrangements” includes any agreement, understanding, scheme, transaction or series of transactions (whether or not legally enforceable).