Section 356OP “Arrangement”F1

(1)

In this Part “arrangement” (except in the phrase “double taxation arrangements”) includes any agreement, understanding, scheme, transaction or series of transactions, whether or not legally enforceable).

(2)

For the purposes of this Part any number of transactions may be regarded as constituting a single arrangement if—

(a)

a common purpose can be discerned in them, or

(b)

there is other sufficient evidence of a common purpose.

Annotations

Textual amendments

F1: Pt. 8ZB inserted (with effect in accordance with s. 81 of the amending Act and also with effect in accordance with Finance (No. 2) Act 2017 (c. 32), s. 39(1)(2))) by Finance Act 2016 (c. 24), s. 77(1)

Notes on Part 8ZB

Modifications

C1: Pt. 8ZB applied (with modifications) by 1992 c. 12, Sch. 1A para. 4(6) (as inserted (with effect in accordance with Sch. 1 paras. 120, 123 of the amending Act) by Finance Act 2019 (c. 1), Sch. 1 para. 14)