Commentary on Sections Overview Overview Section 83: Schemes and arrangements referred to in section 82(4)
194.This section concerns the schemes and arrangements against which these provisions are directed. It fills out condition C in section 82(4), and introduces sections 84 to 88 (which specify the general features of the schemes and arrangements in question). It is based on section 804ZA(11) of ICTA and paragraph 1 of Schedule 28AB to that Act.
195.If a scheme or arrangement is not an underlying-tax scheme or arrangement (as defined in subsection (3)), subsection (2) brings it within this section if one or more of sections 84 to 88 apply to it.
196.In the case of an underlying-tax scheme or arrangement, subsections (4) to (7) modify the application of sections 84 to 88. If one or more of sections 84 to 88 would apply to the scheme or arrangement if the overseas-resident body corporate in question was resident in the United Kingdom, subsection (4) brings the scheme or arrangement within this section.