Section 201 — Finance Act 2014: “Tax advantage” and “tax arrangements”

“Tax advantage” and “tax arrangements” 201 1 This section applies for the purposes of this Part. 2 “ 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.

3 Arrangements are “tax arrangements” if, having regard to all the circumstances, it would be reasonable to conclude that the obtaining of a tax advantage was the main purpose, or one of the main purposes, of the arrangements. 4 “ Arrangements ” includes any agreement, understanding, scheme, transaction or series of transactions (whether or not legally enforceable).