479. Arrangements conferring benefit on participator.

The following provisions apply if: (1) a close company1 is at any time a party to tax avoidance arrangements2; and (2) as a result of those arrangements, a benefit is conferred (whether directly or indirectly) on an individual who is a participator3 in the company or an associate4 of such a participator5. They do not apply, however, if, or to the extent that, the conferral of the benefit gives rise to a charge to tax on the company6 or a charge to income tax on the participator or associate7.

If these provisions apply, there is due from the company, as