Relief not available if purpose of arrangements is improper
This section has no associated Explanatory Notes
26The reliefs provided by paragraph 15 and 19 (and paragraph 21 so far as it relates to those paragraphs) are not available if the arrangements mentioned in paragraph 8—
(a)are not effected for genuine commercial reasons, or
(b)form part of arrangements of which the main purpose, or one of the main purposes, is the avoidance of liability to the tax.