The GAAR1 can only apply where 'tax arrangements' have been entered into. 'Tax arrangements' is given a wide definition, as arrangements where, having regard to all the circumstances, it would be reasonable to conclude that the main purpose, or one of the main purposes of those arrangements is the obtaining of a tax advantage2. 'Tax advantage' also has a wide, non-exhaustive definition. It includes relief or increased relief from tax; repayment or increased repayment of tax; avoidance or reduction of a charge to tax or an assessment to tax; avoidance of a possible assessment to tax; deferral of a
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