Regulation 8 Condition B

Condition B is that, having regard to all the circumstances, it would be reasonable to conclude that the main purpose, or one of the main purposes, of the insurance risk transformation, or of arrangements which the insurance risk transformation forms part of, is to secure a tax advantage for any person.

Where condition B is met, the condition is treated as met when the insurance risk transformation is, or the arrangements referred to in paragraph (1) are, first entered into.

For the purposes of this regulation, “arrangements” include any agreement, understanding, scheme, transaction or series of transactions (whether or not legally enforceable).