(1)A “tax advantage” includes in particular—
(a)relief or increased relief from tax,
(b)repayment or increased repayment of tax,
(c)avoidance or reduction of a charge to tax or an assessment to tax,
(d)avoidance of a possible assessment to tax, and
(e)deferral of a payment of tax or advancement of a repayment of tax.
(2)In determining whether a tax avoidance arrangement has resulted in a tax advantage, regard may be had to the amount of tax that would have been payable in the absence of the arrangement.