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26.—(1) Regulations 19, 21 and 25 do not apply if conditions A and B are met.
(2) Condition A is that the transferor is a party to arrangements under which there is likely to be a transfer of rights or liabilities under the loan relationship by the transferee to another person in circumstances in which—
(a)sections 336 and 340 of CTA; or
(b)regulation 19, 21 or 25,
would not apply.
(3) Condition B is that the purpose, or one of the main purposes, of the arrangements is to obtain a tax advantage for the transferor or a person connected with the transferor.
(4) In this regulation “transfer” includes any arrangement which equates in substance to a transfer.
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