Sch 11A para 3
(1) If it appears to the Treasury— (a) that a scheme of a particular description has been, or might be, entered into for the purpose of enabling any person to obtain a tax advantage, and (b) that it is unlikely that persons would enter into a scheme of that description unless the main purpose, or one of the main purposes, of doing so was the obtaining by any person of a tax advantage, the Treasury may by order designate that scheme for the purposes of this paragraph. (2) A scheme may be designated for the purposes of this paragraph even though the Treasury are of the opinion that no scheme of that description could as a matter of law result in the obtaining by any person of a tax advantage. (3) The order must allocate a reference number to each scheme. (4) In this Schedule “ designated scheme ” means a scheme of a description designated for the purposes of this paragraph.