SCHEDULES

SCHEDULE 61Alternative finance investment bonds

Part 3Transactions relating to underlying assets consisting of land

Supplementary

Relief not available if purpose of arrangements is improper

22

1

The reliefs provided by paragraphs 6 to 12 (and paragraph 18 so far as it relates to those paragraphs) are not available if the arrangements mentioned in paragraph 5(2)—

a

are not effected for genuine commercial reasons, or

b

form part of arrangements of which the main purpose, or one of the main purposes, is the avoidance of liability to tax.

2

In sub-paragraph (1) “tax” means income tax, corporation tax, capital gains tax, stamp duty or stamp duty land tax.