Where the transitional provisions apply, the tax effect (termed the ‘relevant effect’ that the asset-backed arrangement would have had), is to be denied.

‘Simple’ arrangements

Where relief for the contribution under the asset-backed arrangement would have been denied under the provision described at ¶¶377-020, had that provision been in force prior to 22 February 2012, the ‘relevant effect’ is that, in respect of amounts arising on or after that date but before the ‘completion day’ (see ¶¶377-240) the borrower, or a person connected to the borrower;

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