The motive test will be satisfied, and as a result the anti-diversion rule (see ¶764-840) will not apply, where both of the following conditions are met:

Condition A. Where a relevant transaction, or a number of transactions at least one of which is a relevant transaction, has achieved a reduction in UK tax, that reduction is minimal or it was not the main purpose, or one of the main purposes, of the transaction or the transactions taken together to achieve that reduction.

A transaction is a ‘relevant transaction’ if the results of that transaction are reflected in the profits attributed to the permanent establishment.

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