SolvedIEIM405080 | Compliance: Anti-Avoidance
From HM Revenue & Customs · International Exchange of Information Manual
Compliance: Anti-Avoidance
The Regulations include an anti-avoidance measure which is aimed at arrangements taken by any person to avoid the obligations placed upon them by the Regulations.
It is intended that 'arrangements' will be interpreted widely and the effect of the rule is that the Regulations will apply, as if the arrangements had not been entered into.