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A targeted anti-avoidance rule ('TAAR' ¹) applies to losses of all persons. It provides that an allowable loss does not include a loss that accrues to a company directly or indirectly in consequence of, or in connection with, any 'arrangements' and the main purpose, or one of the main purposes, of the arrangements is to secure a tax advantage², whether this is in respect of capital gains tax, corporation tax or income tax³. For this restriction of an allowable loss, it is not necessary for the loss to accrue at a time when there are capital gains against which the loss could have been set, and the tax advantage may be obtained by any person⁴.

'Arrangements' include any agreement, understanding, scheme, transactions or series of transactions, whether or not legally enforceable⁵.

For the purpose of these provisions, a 'tax advantage' means⁶:

1. Ìý

   (a)ÌýÌýÌýÌý relief or increased relief from tax

2. Ìý

   (b)ÌýÌýÌýÌý repayment or increased repayment of tax

3. Ìý

   (c)ÌýÌýÌýÌý avoidance