Paragraph 11 F1

a person has made a return, claim or election on the basis that a tax advantage arises from the arrangements,

a notice given to the person under paragraph 12 of Schedule 43 to, paragraph 8(2) or 9(2) of Schedule 43A to or paragraph 8(2) of Schedule 43B to FA 2013 stated that the tax advantage was to be counteracted under the general anti-abuse rule,

the tax advantage has been counteracted (in whole or in part) under the general anti-abuse rule, and

the counteraction is final.