Section 154A | Anti-avoidance ^F1

(1)Subsection (2) applies if—

(a)a person makes a loss in a relevant transaction, and

(b)that loss arises directly or indirectly in consequence of, or otherwise in connection with, relevant tax avoidance arrangements.

(2)The person is not to be given loss relief under section 152 for the loss.

(3)Subsection (4) applies if—

(a)a person has income on which income tax is chargeable under, or by virtue of, a relevant section 1016 provision, and

(b)that income arises directly or indirectly in consequence of, or otherwise in connection with, relevant tax avoidance arrangements.

(4)The person is not to be given loss relief against that income under section 152.

(5)In this section “relevant tax avoidance arrangements” means arrangements—

(a)to which the person is party, and

(b)the main purpose, or one of the main purposes, of which is to obtain a reduction in tax liability by means of loss relief under section 152.

(6)In subsection (5) “arrangements” includes any agreement, understanding, scheme, transaction or series of transactions (whether or not legally enforceable).