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.