Sch 9A para 2
(1) The Commissioners shall not give a direction under this Schedule by reference to a relevant event if they are satisfied that— (a) the change in the treatment of the person , or (b) the transaction in question, had as its main purpose or, as the case may be, as each of its main purposes a genuine commercial purpose unconnected with the fulfilment of the condition specified in paragraph 1(3) above. (2) This paragraph shall not apply where the relevant event is the termination of a person's treatment as a member of a group by a notice under section 43C(1) or (3).