412. Distributions derived from transactions not designed to reduce tax.

A dividend or other distribution1 also falls into an exempt class2 if it is made in respect of relevant profits3. 'Relevant profits' means any profits available for distribution at the time that the distribution is made, other than profits that reflect the results of a transaction, or of one or more of a series of transactions, where the transaction or series of transactions achieve a reduction (other than a negligible reduction) in United Kingdom4 tax, and the purpose or one of the main purposes of that transaction or series of transactions is to achieve that reduction