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

If a tax advantage arises out of a transaction that is part of the arrangements, the legislation 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 tax advantage. The purpose of the arrangements is determined by the purpose of the participants in entering into the arrangements. If any participant has a main purpose of achieving a tax advantage, that will constitute a main purpose of the arrangements.