51茶馆

鈥楢rrangement鈥� is defined in section 84 of the Finance Act 2019 as including 鈥渁ny scheme, transaction, or series of transactions鈥�. This is not exhaustive, and so the scope of what could be an arrangement is potentially broad. This ensures that all relevant arrangements are indeed reportable.

It will generally be necessary to look at any arrangement holistically, rather than looking at an arrangement as a series of small steps or separate transactions. This is clear from the reference to a 鈥榮eries of transactions鈥� in section 84.

Where there is a pre-existing arrangement which is extended, this would not normally be viewed as a new arrangement, unless there is some material change to the arrangement.