For the purposes of this Act, "allowable loss" does not include a loss accruing to a person if—
it accrues to the person directly or indirectly in consequence of, or otherwise in connection with, any arrangements, and
the main purpose, or one of the main purposes, of the arrangements is to secure a tax advantage.
For the purposes of subsection (1)—
"arrangements" includes any agreement, understanding, scheme, transaction or series of transactions (whether or not legally enforceable), and
"tax advantage" means— and for the purposes of this definition "tax" means capital gains tax, corporation tax or income tax.
(a)relief or increased relief from tax,
(b)repayment or increased repayment of tax,
(c)the avoidance or reduction of a charge to tax or an assessment to tax, or
(d)the avoidance of a possible assessment to tax,
For the purposes of subsection (1) it does not matter—
whether the loss accrues at a time when there are no chargeable gains from which it could otherwise have been deducted, or
whether the tax advantage is secured for the person to whom the loss accrues or for any other person.