SCHEDULES

SCHEDULE 22 Prevention of exploitation of SCHEDULE 2 TO ITTOIA 2005 (SO FAR AS RELATING TO OVERLAP PROFIT)

Part IV Interpretation

Relevant transactions for purposes of paragraphs 1, 3, 6 and 7

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Any self-cancelling transaction or transaction with a connected person is a relevant transaction for the purposes of F1paragraphs 1, 3 and 7 above unless—

(a)

the transaction is entered into exclusively for bona fide commercial reasons; or

(b)

the obtaining of a tax advantage is not the main benefit that could reasonably be expected to arise from the entering into of the transaction.