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Version date: 1 January 2020 - onwards
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753E. Anti-avoidance.

(1) In this section -

'the Acts' means -

(a) the Tax Acts,

(b) the Capital Gains Tax Acts,

(c) the Act of 1999, and the enactments amending or extending that Act, and

(d) the Value-Added Tax Consolidation Act 2010, and the enactments amending or extending that Act,

and any instrument made thereunder and any instrument that is made under any other enactment and which relates to those Acts;

'tax advantage' has the same meaning as it has in section 811C;

'transaction period' means the period after -

(a) qualifying securities have been obtained from a lender under a stock borrowing, or

(b) a stock transfer has taken place under a repurchase agreement,

but before the corresponding stock return has taken place.

(2) This Chapter shall not apply to a financial transaction, unless it would be reasonable to consider that the financial transaction -

(a) has been undertaken for bona fide commercial reasons, and

(b) does not form part of any arrangement or scheme of which the main purpose, or one o

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