PART 5Promoters of tax avoidance schemes
Introduction
234Meaning of “relevant proposal” and “relevant arrangements”
1
“Relevant proposal” means a proposal for arrangements which (if entered into) would be relevant arrangements (whether the proposal relates to a particular person or to any person who may seek to take advantage of it).
2
Arrangements are “relevant arrangements” if—
a
they enable, or might be expected to enable, any person to obtain a tax advantage, and
b
the main benefit, or one of the main benefits, that might be expected to arise from the arrangements is the obtaining of that advantage.
3
“Tax advantage” includes—
a
relief or increased relief from tax,
b
repayment or increased repayment of tax,
c
avoidance or reduction of a charge to tax or an assessment to tax,
d
avoidance of a possible assessment to tax,
e
deferral of a payment of tax or advancement of a repayment of tax, and
f
avoidance of an obligation to deduct or account for tax.
4
“Arrangements” includes any agreement, scheme, arrangement or understanding of any kind, whether or not legally enforceable, involving a single transaction or two or more transactions.