Section 357YH | Countering effect of avoidance arrangements
From legislation.gov.uk
(1)Any ... tax advantages that would (in the absence of this section) arise from relevant avoidance arrangements are to be counteracted by the making of such adjustments as are just and reasonable in relation to amounts to be brought into account for the purposes of this Part.
(2)Any adjustments required to be made under this section (whether or not by an officer of Revenue and Customs) may be made by way of an assessment, the modification of an assessment, amendment or otherwise.
(3)For the meaning of “relevant avoidance arrangements” and “tax advantage” see section 357YI.