This applies for relevant periods beginning before 1 January 2013.

CTA09/S18H: Condition A

Condition A of the motive test in CTA09/S18H(2) is met where a relevant transaction, or one or more transactions at least one of which was a relevant one, achieves a reduction in UK tax and either

the reduction was minimal, or

it was not the main purpose, or one of the main purposes, of the transaction, or of those transactions taken together, to achieve the reduction.

In determining whether condition A has been satisfied, the following three questions need to be addressed.

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