Section 809EZF | Disguised investment management fees: anti-avoidance
From legislation.gov.uk
In determining whether section 809EZA applies in relation to an individual, no regard is to be had to any arrangements the main purpose, or one of the main purposes, of which is to secure that that section does not apply in relation to—
(a)the individual, or
(b)the individual and one or more other individuals.