This section has no associated Explanatory Notes
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)—U.K.
(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.