PART 5The general anti-avoidance rule
Artificial tax avoidance arrangements
63Tax avoidance arrangements
(1)
An arrangement (or series of arrangements) is a tax avoidance arrangement if, having regard to all the circumstances, it would be reasonable to conclude that obtaining a tax advantage is the main purpose, or one of the main purposes, of the arrangement.
(2)
An “arrangement”—
(a)
includes any transaction, scheme, action, operation, agreement, grant, understanding, promise, undertaking or event (whether legally enforceable or not), and
(b)
may comprise one or more stages or parts.