Income Tax Act 2007 section 517Q

"Arrangement"

Section 517Q defines the term "arrangement" as used in the provisions dealing with profits and gains from disposals concerned with land in the United Kingdom.

• The term "arrangement" is defined very broadly, covering agreements, understandings, schemes, transactions, or series of transactions, whether or not legally enforceable.
• The definition does not apply to the separate phrase "double taxation arrangements", which retains its own distinct meaning.
• Multiple transactions can be treated as a single arrangement if a common purpose can be identified in them, or if there is other sufficient evidence of a common purpose.
• This wide definition is designed to prevent avoidance by ensuring that informal or non-binding deals are caught alongside formal, legally binding ones.