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HMRC internal manual

Capital Gains Manual

Administration: losses: targeted rules to prevent the contrived creation of capital losses - definition of arrangements

The term “arrangements” is widely drawn to include any agreement,understanding, scheme, transaction or series of transactions, whether or not legallyenforceable.

Whether a transaction forms part of a series of transactions, or a scheme, or arrangementis in general a question of fact, but this conclusion will follow in any case where onetransaction would not have taken place without another transaction, or would have takenplace on different terms without that other transaction. However, it is not necessary thattransactions must depend on each other in this way in order that they form part of ascheme or arrangements.