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SCHEDULES

SCHEDULE 22Prevention of exploitation of Schedule 20 to Finance Act 1994

Part IVInterpretation

Relevant transactions for purposes of paragraphs 1, 3, 6 and 7

15Any self-cancelling transaction or transaction with a connected person is a relevant transaction for the purposes of paragraphs 1, 3, 6 and 7 above unless—

(a)the transaction is entered into exclusively for bona fide commercial reasons; or

(b)the obtaining of a tax advantage is not the main benefit that could reasonably be expected to arise from the entering into of the transaction.