Corporation Tax Act 2010 section 356OP

"Arrangement"

Section 356OP defines the term "arrangement" as used throughout this Part of the Act, and explains when multiple transactions can be treated as a single arrangement.

• An "arrangement" includes any agreement, understanding, scheme, transaction, or series of transactions, whether or not legally enforceable.
• The definition does not apply to the phrase "double taxation arrangements", which retains its own separate meaning.
• Multiple transactions can be regarded as a single arrangement if a common purpose can be identified across them.
• Even without an obvious common purpose, other sufficient evidence of a shared objective can link transactions into one arrangement.