17(1)A transaction achieves a reduction in United Kingdom tax if, had the transaction not been effected, any person—U.K.
(a)would have been liable for any such tax or for a greater amount of any such tax; or
(b)would not have been entitled to a relief from or repayment of any such tax or would have been entitled to a smaller relief from or repayment of any such tax.
(2)In this Part of this Schedule and section 748(3) “United Kingdom tax” means income tax, corporation tax or capital gains tax.