[215 Transactions to obtain tax advantages]

[215  Transactions to obtain tax advantages]

[(1)     Allowances under this Part are restricted[, and balancing charges are imposed or increased,] under the applicable sections if [B and S enter into a relevant transaction] that either—

(a)     has an avoidance purpose, or

(b)     is part of, or occurs as a result of, a scheme or arrangement that has an avoidance purpose.

(2)     Subsection (1)(b) may be satisfied—

(a)     whether the scheme or arrangement was made before or after the relevant transaction was entered into, and

(b)     whether or not the scheme or arrangement is legally enforceable.

(3)

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