PART 5The general anti-avoidance rule
Artificial tax avoidance arrangements
63Tax avoidance arrangements
1
An arrangement (or series of arrangements) is a tax avoidance arrangement if, having regard to all the circumstances, it would be reasonable to conclude that obtaining a tax advantage is the main purpose, or one of the main purposes, of the arrangement.
2
An “arrangement”—
a
includes any transaction, scheme, action, operation, agreement, grant, understanding, promise, undertaking or event (whether legally enforceable or not), and
b
may comprise one or more stages or parts.