Skip to content
Solved
SearchBrowse
Sign in

Contents

Legislation
Taxation (International and Other Provisions) Act 2010

Crossheading Meaning of certain expressions that first appear in section 147

  • Section 149 “Actual provision” and “affected persons”
  • Section 150 “Transaction” and “series of transactions”
  • Section 151 “Arm's length provision”
  • Section 152 Arm's length provision where actual provision relates to securities
  • Section 153 Arm's length provision where security issued and guarantee given
  • Section 153A Certain guarantees not capable of being arm’s length
  • Section 153B Election for deemed guarantee
  • Section 154 Interpretation of sections 153A and 153B
  • Section 155 “Potential advantage” in relation to United Kingdom taxation
  • Section 156 “Losses” and “profits”
  1. Meaning of certain expressions that first appear in section 147
  2. “Transaction” and “series of transactions”

Section 150 | “Transaction” and “series of transactions”

From legislation.gov.uk

(1)In this Part “transaction” includes arrangements, understandings and mutual practices (whether or not they are, or are intended to be, legally enforceable).

(2)References in this Part to a series of transactions include references to a number of transactions each entered into (whether or not one after the other) in pursuance of, or in relation to, the same arrangement.

(3)A series of transactions is not prevented by reason only of one or more of the matters mentioned in subsection (4) from being regarded for the purposes of this Part as a series of transactions by means of which provision has been made or imposed as between any two persons.

(4)Those matters are—

(a)that there is no transaction in the series to which both those persons are parties,

(b)that the parties to any arrangement in pursuance of which the transactions in the series are entered into do not include one or both of those persons, and

(c)that there is one or more transactions in the series to which neither of those persons is a party.

(5)In this section “arrangement” means any scheme or arrangement of any kind (whether or not it is, or is intended to be, legally enforceable).

PreviousNext
PrivacyTerms