19U.K.In paragraph 2 of Schedule 7 (restrictions on availability of group relief) after sub-paragraph (4) insert—
“(4A)Group relief is not available if the transaction—
(a)is not effected for bona fide commercial reasons, or
(b)forms part of arrangements of which the main purpose, or one of the main purposes, is the avoidance of liability to tax.
“Tax” here means stamp duty, income tax, corporation tax, capital gains tax or tax under this Part.”