# Taxation (International and Other Provisions) Act 2010, Section 217E: Tax design condition


(1) The tax design condition is met if it is reasonable to assume that the structure of—
(a) the transaction or series of transactions by which the provision to which the unassessed transfer pricing profits relate is imposed, or
(b) any arrangements to which the transaction or series of transactions relate,
is designed to have the effect of reducing, eliminating or delaying the liability of any person to pay UK tax.
(2) In subsection (1)—
(a) “arrangements” means any scheme or arrangement of any kind (whether or not it is, or is intended to be, legally enforceable);
(b) “UK tax” means income tax, corporation tax or capital gains tax.

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Source: https://www.legislation.gov.uk/ukpga/2010/8/section/217E (the official version)
Page: https://openlegislation.uk/taxation-international-and-other-provisions-act-2010/section-217E
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.