In this Schedule—

• “arrangements” includes any scheme, agreement, understanding, transaction or series of transactions (whether or not legally enforceable),

• “authorised investment fund” means—

  1. a

     an open-ended investment company within the meaning of section 613 of CTA 2010, or

  2. b

     an authorised unit trust within the meaning of section 616 of that Act,

• “business” includes any trade, profession or vocation,

• “employer” has the same meaning as in Part 4 of FA 2004 (see section 279(1) of that Act),

• “genuine diversity of ownership condition” means—

  1. a

     in the case of an offshore fund, the genuine diversity of ownership condition in regulation 75 of the Offshore Funds (Tax) Regulations 2009 (S.I. 2009/3001), and

  2. b

     in the case of an authorised investment fund, the genuine diversity of ownership condition in regulation 9A of the Authorised Investment Fund (Tax) Regulations 2006 (S.I. 2006/964),

• “material provision” has the same meaning as in paragraph 2,

• “non-UK tax” has the meaning given by section 187 of CTA 2010,

• “offshore fund” has the same meaning as in section 354 of TIOPA 2010 (see section 355 of that Act),

• “the overseas party” has the meaning given by paragraph 1(2),

• “overseas pension scheme” has the same meaning as in Part 4 of FA 2004 (see section 150(7) of that Act),

• “participator” has the same meaning as in Part 10 of CTA 2010 (see section 454 of that Act),

• “partnership” includes an entity established under the law of a country or territory outside the United Kingdom of a similar character to a partnership, and “member” of a partnership is to be construed accordingly,

• “related individual” and “the resident party” have the meanings given by paragraph 1(2),

• “tax advantage” includes—

  1. a

     relief or increased relief from income tax or corporation tax,

  2. b

     repayment or increased repayment of income tax or corporation tax,

  3. c

     avoidance or reduction of a charge or an assessment to income tax or corporation tax,

  4. d

     avoidance of a possible assessment to income tax or corporation tax,

  5. e

     deferral of a payment of tax or advancement of a repayment of tax, and

  6. f

     avoidance of an obligation to deduct or account for tax,

• “tax period” has the meaning given by paragraph 5(7),

• “the tax reduction” has the meaning given by paragraph 5(2), and

• “trust” includes arrangements—

  1. a

     which have effect under the law of a country or territory outside the United Kingdom, and

  2. b

     under which persons acting in a fiduciary capacity hold and administer property on behalf of other persons,

  and “beneficiaries”, in relation to such arrangements, is to be construed accordingly.