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Official guidance
Capital Gains Manual

CG47320P · Capital Gains Manual: Companies and Groups of Companies: Groups of companies: Anti-gain buying rules in Finance Act 2006

  • CG47320 · Anti-gain buying rules in FA 2006 - general
  • CG47321 · Targeted anti-gain buying rule - general
  • CG47323 · Targeted anti-gain buying rule - definition of change of ownership
  • CG47324 · Targeted anti-gain buying rule - definition of arrangements
  • CG47325 · Targeted anti-gain buying rule - definition of tax advantage
  • CG47326 · Targeted anti-gain buying rule - is a tax advantage a main purpose?
  • CG47327 · Targeted anti-gain buying rule - tax advantage - choice of commercial options
  • CG47331 · Targeted anti-gain buying rule - effect of the new legislation
  • CG47332 · Targeted anti-gain buying rule - definition of pre-change asset
  • CG47333 · Targeted anti-gain buying rule - asset no longer regarded as a pre-change asset
  • CG47334 · Targeted anti-gain buying rule - time of loss accrual and company to which tax advantage arises
  • CG47335 · Targeted anti-gain buying rule - limited exception to the rule for gain assets held before change of ownership
  • CG47336 · Targeted anti-gain buying rule - interaction of legislation with pre-existing losses
  • CG47337 · Targeted anti-gain buying rule - example
  • CG47338 · Targeted anti-gain buying rule - commencement
  • CG47322 · Targeted anti-gain buying rule - general
  • CG47328 · Targeted anti-gain buying rule - tax advantage - choice of commercial options
  • CG47329 · Targeted anti-gain buying rule - choice of commercial options
  1. Capital Gains Manual: Companies and Groups of Companies: Groups of companies: Anti-gain buying rules in Finance Act 2006: Contents
  2. Targeted anti-gain buying rule - definition of arrangements

CG47324 | Targeted anti-gain buying rule - definition of arrangements

From HM Revenue & Customs · Capital Gains Manual

The term “arrangements” is widely drawn to include any agreement, understanding, scheme, transaction or series of transactions, whether or not legally enforceable.

Whether a transaction forms part of a series of transactions, or a scheme, or arrangement is in general a question of fact, but this conclusion will follow in any case where one transaction would not have taken place without another transaction, or would have taken place on different terms without that other transaction. However, it is not necessary that transactions must depend on each other in this way in order that they form part of a scheme or arrangements.

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