Section 356OP | “Arrangement” ^F1

(1)In this Part “arrangement” (except in the phrase “double taxation arrangements”) includes any agreement, understanding, scheme, transaction or series of transactions, whether or not legally enforceable).

(2)For the purposes of this Part any number of transactions may be regarded as constituting a single arrangement if—

(a)a common purpose can be discerned in them, or

(b)there is other sufficient evidence of a common purpose.