Meaning of “transaction" and “series of transactions"U.K.
3(1)In this Schedule “transaction” includes arrangements, understandings and mutual practices (whether or not they are, or are intended to be, legally enforceable).
(2)References in this Schedule to a series of transactions include references to a number of transactions each entered into (whether or not one after the other) in pursuance of, or in relation to, the same arrangement.
(3)A series of transactions shall not be prevented by reason only of one or more of the matters mentioned in sub-paragraph (4) below from being regarded for the purposes of this Schedule as a series of transactions by means of which provision has been made or imposed as between any two persons.
(4)Those matters are—
(a)that there is no transaction in the series to which both those persons are parties;
(b)that the parties to any arrangement in pursuance of which the transactions in the series are entered into do not include one or both of those persons; and
(c)that there is one or more transactions in the series to which neither of those persons is a party.
(5)In this paragraph, “arrangement” means any scheme or arrangement of any kind (whether or not it is, or is intended to be, legally enforceable).
Modifications etc. (not altering text)
C1Sch. 28AA para. 3 applied (with effect in accordance with Sch. 17 para. 13 of the affecting Act) by Finance Act 2009 (c. 10), Sch. 17 para. 12(5)