(1) Relief shall not be given to any person under Part 8 in respect of any payment of interest, including interest treated as a charge on income, if a scheme has been effected or arrangements have been made such that the sole or main benefit that might be expected to accrue to that person from the transaction under which the interest is paid is the obtaining of a reduction in tax liability by means of any such relief.
(2) Where relief in respect of interest paid, being interest treated as a charge on income, is claimed by virtue of section 420(6), any question under this section as to what benefit might be expected to accrue from the transaction under which that interest is paid shall be determined by reference to the claimant company (within the meaning of section 411(2)) and the surrendering company (within the meaning of that section) taken together.