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[F1PART 3AE+WGENERAL ANTI-AVOIDANCE RULE

Proceedings before a court or tribunalE+W

81HProceedings in connection with the general anti-avoidance ruleE+W

In proceedings before a court or the tribunal in connection with the general anti-avoidance rule, it is for WRA to show—

(a)that there is an artificial tax avoidance arrangement, and

(b)that the adjustments made (or to be made) to counteract the tax advantage arising from the arrangement are just and reasonable.]