Related Commentary  Related Cases

205(1)  This section applies for the purposes of this Chapter.

205(2)  “Judicial ruling” means a ruling of a court or tribunal on one or more issues.

205(3)  A judicial ruling is “relevant” to the chosen arrangements if–

(a)it relates to tax arrangements,

(b)the principles laid down, or reasoning given, in the ruling would, if applied to the chosen arrangements, deny the asserted advantage or a part of that advantage, and

(c)it is a final ruling.

205(4)  A judicial ruling is a “final ruling” if it is–

(a)a ruling of the Supreme Court, or

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