201“Tax advantage” and “tax arrangements”U.K.
(1)This section applies for the purposes of this Part.
(2)“Tax advantage” includes—
(a)relief or increased relief from tax,
(b)repayment or increased repayment of tax,
(c)avoidance or reduction of a charge to tax or an assessment to tax,
(d)avoidance of a possible assessment to tax,
(e)deferral of a payment of tax or advancement of a repayment of tax, and
(f)avoidance of an obligation to deduct or account for tax.
(3)Arrangements are “tax arrangements” if, having regard to all the circumstances, it would be reasonable to conclude that the obtaining of a tax advantage was the main purpose, or one of the main purposes, of the arrangements.
(4)“Arrangements” includes any agreement, understanding, scheme, transaction or series of transactions (whether or not legally enforceable).