Introduction Tax avoidance arrangements
91.Schedule 2A Paragraph 18 denies relief if a pre-completion transaction forms part of tax avoidance arrangements; this requires consideration of the purpose or purposes of the original purchaser.
92.Sub-paragraph (1) denies relief under paragraph 15 and paragraph 16 if the assignment of rights and/or the qualifying subsale (as the case may be) forms part of any tax avoidance arrangements.
93.Sub-paragraph (2) sets out the meaning of “tax avoidance arrangements”.
94.Sub-paragraph (3) sets out the meaning of “tax advantage”.
95.Sub-paragraph (4) sets out the meaning of “arrangements”.
96.Sub-paragraph (5) provides that (for the avoidance of doubt) nothing in paragraphs 12, 13 and 14 (the minimum consideration rule and the calculation of the first minimum amount and the second minimum amount) affects the breadth of sections 75A -75C FA 2003 (anti-avoidance rules).