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“Tax advantage� has the meaning given in TCGA92/S184D. There are four legs tothis definition, which cover relief, repayments, the amount of a charge, and theassessment of corporation tax.

If a tax advantage arises out of a transaction that is part of the arrangements, thelegislation asks whether the main purpose or one of the main purposes of the arrangements(referred to as “a main purpose� in this guidance) is to achieve a taxadvantage. The purpose of the arrangements is determined by the purpose of theparticipants in entering into the arrangements. If any participant has a main purpose ofachieving a tax advantage, that will constitute a main purpose of the arrangements.