IEIM730010 - Meaning of Arrangement

‘Arrangement’ is defined in section 84 of the Finance Act 2019 as including “any scheme, transaction, or series of transactions”. This is not exhaustive, and so the scope of what could be an arrangement is potentially broad. This ensures that all relevant arrangements are indeed reportable.

It will generally be necessary to look at any arrangement holistically, rather than looking at an arrangement as a series of small steps or separate transactions. This is clear from the reference to a ‘series of transactions’ in section 84.

Where there is a pre-existing arrangement which is extended, this would not normally be viewed as a new arrangement, unless there is some material change to the arrangement.