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HMRC internal manual

Business Leasing Manual

Sale of lessor companies and similar arrangements: anti-avoidance: meaning of ‘arrangements’

Section 435 CTA2010

The meaning of ‘arrangements’ is widely drawn to encompass ‘any agreement, understanding, scheme, transaction or series of transactions’. The arrangements do not have to be legally enforceable and the company that obtains the tax advantage does not have to be a party to the arrangement.