Commercial transactions
25Chapter 2 of Part 7A of ITEPA 2003 does not apply by reason of a relevant step within paragraph 1 which is treated as being taken by a person (“P”) if—
(a)P is treated as taking a relevant step by that paragraph by reason of the payment of a sum of money by way of a loan,
(b)the loan is (at the time it is made) a loan on ordinary commercial terms within the meaning of section 176 of ITEPA 2003, ignoring conditions B and C in that section, and
(c)there is no connection (direct or indirect) between the relevant step and a tax avoidance arrangement.