PART 3Diverted profits tax
Interpretation
111“Transaction” and “series of transactions”
1
In this Part “transaction” includes arrangements, understandings and mutual practices (whether or not they are, or are intended to be, legally enforceable).
2
References in this Part to a series of transactions include references to a number of transactions each entered into (whether or not one after the other) in pursuance of, or in relation to, the same arrangement.
3
A series of transactions is not prevented by reason only of one or more of the matters mentioned in subsection (4) from being regarded for the purposes of this Part as a series of transactions by means of which provision has been made or imposed as between any two persons.
4
Those matters are—
a
that there is no transaction in the series to which both those persons are parties,
b
that the parties to any arrangement in pursuance of which the transactions in the series are entered into do not include one or both of those persons, and
c
that there is one or more transactions in the series to which neither of those persons is a party.
5
In this section “arrangement” means any scheme or arrangement of any kind (whether or not it is, or is intended to be, legally enforceable).