Despite the announcement in April 2009 that the FHL rules were to be abolished, that was not the eventual outcome. Indeed, the FA 2011 reform of the rules largely adds to the original FA 1984 legislative provisions as rewritten into ITTOIA 2005 and CTA 2009. The policy background to the FA 1984 provisions is considered in Chapter 1. In this chapter, it is sensible to start by analysing the original legislative provisions in more detail.

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