Section 234 — Finance Act 2014: Meaning of “relevant proposal” and “relevant arrangements”

Meaning of “relevant proposal” and “relevant arrangements” 234 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.