SCHEDULES

SCHEDULE 22 Prevention of exploitation of Schedule 20 to Finance Act 1994

Part IV Interpretation

Relevant transactions for purposes of paragraph 10

20

1

Any transaction with a connected person is a relevant transaction for the purposes of paragraph 10 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.

2

A person is connected with another person for the purposes of this paragraph if they are connected with each other within the meaning of section 839 of the Taxes Act 1988.