A7.221 Loss schemes

A7.221 Loss schemes

The sixth hallmark – loss schemes – covers arrangements where1:

  1.  

    •     the promoter expects more than one individual to implement the same, or substantially the same, arrangements, and

  2.  

    •     the arrangements are such that an informed observer (having studied them) could reasonably conclude that:

    1.  

      (i)     a main benefit of those arrangements which could be expected to accrue to some or all of the individuals participating in them is the provision of losses

    2.  

      (ii)     the arrangements, or their structure, contain elements which are unlikely to have been entered were it not for the provision of those losses, and

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