Section 217E | Tax design condition ^F1

(1)The tax design condition is met if it is reasonable to assume that the structure of—^F1

(a)the transaction or series of transactions by which the provision to which the unassessed transfer pricing profits relate is imposed, or^F1

(b)any arrangements to which the transaction or series of transactions relate,^F1

is designed to have the effect of reducing, eliminating or delaying the liability of any person to pay UK tax.

(2)In subsection (1)—^F1

(a)“arrangements” means any scheme or arrangement of any kind (whether or not it is, or is intended to be, legally enforceable);^F1

(b)“UK tax” means income tax, corporation tax or capital gains tax.^F1