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PART 5 SThe general anti-avoidance rule

Artificial tax avoidance arrangementsS

63Tax avoidance arrangementsS

(1)An arrangement (or series of arrangements) is a tax avoidance arrangement if, having regard to all the circumstances, it would be reasonable to conclude that obtaining a tax advantage is the main purpose, or one of the main purposes, of the arrangement.

(2)An “arrangement”—

(a)includes any transaction, scheme, action, operation, agreement, grant, understanding, promise, undertaking or event (whether legally enforceable or not), and

(b)may comprise one or more stages or parts.

Commencement Information

I1S. 63 in force at 1.4.2015 by S.S.I. 2015/110, art. 2(1)