F1PART 3AGENERAL ANTI-AVOIDANCE RULE
Proceedings before a court or tribunal
81HProceedings in connection with the general anti-avoidance rule
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.