11U.K.For the purposes of paragraph 7 a person is “an enabling participant” in the arrangements if—
(a)that person is a person (other than T) who enters into the arrangements or a transaction forming part of the arrangements,
(b)without that person's participation in the arrangements or transaction (or the participation of another person in the arrangements or transaction in the same capacity as that person), the arrangements could not be expected to result in a tax advantage for T, and
(c)when that person entered into the arrangements or transaction, that person knew or could reasonably be expected to know that what was being entered into was abusive tax arrangements or a transaction forming part of such arrangements.