BLM82040 - Sale of lessor companies and similar arrangements: anti- avoidance: meaning of ‘arrangements’ (FA06/SCH10/PARA38A (5))


‘Arrangements’ has the same meaning in the context of paragraph 38A as in paragraph 38. The meaning is widely drawn to encompass 'any agreement, understanding, scheme, transaction or series of transactions'. The arrangements do not have to be legally enforceable and the company that obtains the tax advantage does not have to be a party to the arrangement.