Corporation Tax Act 2010 section 937N

Meaning of "scheme"

Section 937N provides a deliberately broad definition of the term "scheme" for the purposes of the risk transfer scheme provisions in this Part of the Act.

• The term "scheme" is defined very widely to cover any scheme, arrangements or understanding of any kind whatsoever.
• A scheme does not need to be legally enforceable to fall within the definition.
• A scheme may consist of a single transaction or two or more transactions.
• The breadth of this definition is intended to prevent avoidance by structuring arrangements in a way that might escape a narrower definition.