This part of GOV.UK is being rebuilt – find out what beta means

HMRC internal manual

International Manual

Arbitrage: legislation and principles - receipts: meaning of scheme for receipts cases

As with the deductions rules, it is necessary that the arrangements giving rise to the arbitrage constitute a scheme. However, whereas it is necessary for the deductions rules that the scheme is a qualifying scheme which includes a hybrid entity or instrument, it is not necessary (for the receipts rules to apply) for the scheme to be a qualifying scheme.