Paragraph 3

an amount of foreign tax is paid F1or payable by the claimant, and

at the time when the claimant entered into the scheme or arrangement, it could reasonably be expected that the effect F2on the foreign tax total of that amount being so paid or payable would be to increase it by less than the amount allowable to the claimant as a credit in respect of the payment of that amount of foreign tax.

aggregating the amounts of foreign tax paid or payable in respect of the transaction or transactions forming part of the scheme or arrangement by persons party to, or concerned in, the scheme or arrangement, and

taking into account any reliefs, deductions, reductions or allowances against or in respect of any tax that arise to the persons party to, or concerned in, the scheme or arrangement (including any reliefs, deductions, reductions or allowances arising to any one or more of those persons as a consequence of F3that amount of foreign tax being paid or payable by the claimant).