817RI. Specified arrangements

(1) For the purposes of this section, ‘specified arrangement’ means an arrangement that is within one of the classes of arrangements specified in Schedule 34.

(2) A specified arrangement which—

(a) would, but for the operation of this section, contain the hallmark described in paragraph (3) of category A of the hallmarks,

(b) satisfies the main benefit test referred to in Annex IV of the Directive, and

(c) meets the conditions specified in subsection (3),

shall be deemed not to contain the hallmark described in paragraph (3) of category A of the hallmarks.

(3) The conditions referred to in subsection (2) are that—

(a) the tax advantage arises solely by virtue of the arrangement being within one of the classes of arrangements specified in Schedule 34, and

(b) the specified arrangement is not a tax avoidance transaction within the meaning of section 811C.