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.