Taxation (International and Other Provisions) Act 2010 section 258

Schemes and series of transactions

Section 258 clarifies that any reference to a "scheme" or "series of transactions" in the relevant provisions is to be interpreted broadly, covering arrangements that may not be immediately obvious as forming part of a single plan.

• The section provides an interpretative rule for understanding references to schemes and series of transactions within the legislation.
• It ensures that broadly connected arrangements can be treated as forming part of a single scheme or series, even if they appear separate on the surface.
• This prevents taxpayers from artificially breaking up what is in substance one arrangement into apparently unrelated steps to avoid the application of the rules.
• The provision is derived from section 30(1) of the Finance (No 2) Act 2005 and was amended by the Finance Act 2016.