The following examples illustrate situations where HMRC would, or would not, consider that the rule applies. The question of whether there is a main purpose of obtaining a tax advantage is not considered in detail; a real case will depend on its particular facts but it would be highly unlikely that there would be no such main purpose in a case corresponding to an example where HMRC consider that the rule would apply.

The grouping, and therefore also the numbering, of the examples differs to that in the draft versions of the guidance that were published for consultation.

Examples of situations where HMRC considers that the rule would apply

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