Section 1217RM | Transactions not entered into for genuine commercial reasons
From legislation.gov.uk
(1)A transaction is to be ignored for the purpose of determining orchestra tax relief so far as the transaction is attributable to arrangements (other than tax avoidance arrangements) entered into otherwise than for genuine commercial reasons.
(2)In this section “arrangements” and “tax avoidance arrangements” have the same meaning as in section 1217RL.