Related Commentary  Related HMRC Manuals

938P(1)  A scheme is a tax mismatch scheme if condition A or B is met.

938P(2)  Condition A is that, at the time the scheme is entered into, there is no practical likelihood that the scheme will fail to secure a relevant tax advantage of £2 million or more.

938P(3)  The Treasury may by order substitute a higher amount for the amount for the time being specified in subsection (2).

938P(4)  Any such substitution is to have effect in relation to schemes entered into on or after the day on which the order comes into force.

938P(5)  Condition B is that–

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