19(1) Any loss-related tax advantage that would (in the absence of this section) arise from relevant tax arrangements is to be counteracted by the making of such adjustments as are just and reasonable.
19(2) Any adjustments required to be made under this section (whether or not by an officer of Revenue and Customs) may be made by way of–
(b)the modification of an assessment,
(c)amendment or disallowance of a claim,
19(3) For the purposes of this section arrangements are “relevant tax arrangements” if conditions A and B are met.