s 212LA Limiting conditions
(1) The qualifying change meets one of the limiting conditions if condition A, B, C or D is met. (2) Condition A is that the amount of the relevant excess of allowances is £50 million or more. (3) Condition B is that the amount of the relevant excess of allowances— (a) is £2 million or more but less than £50 million, and (b) is not insignificant as a proportion of the total amount or value of the benefits derived by any relevant person by virtue of the qualifying change or change arrangements. (4) “ Relevant person ” means a person who, at the end of the relevant day, is— (a) a principal company of C, (b) a person carrying on the relevant activity in partnership, or (c) a person who is connected to a person within paragraph (a) or (b) (within the meaning of section 1122 of CTA 2010). (5) Condition C is that— (a) the amount of the relevant excess of allowances is less than £2 million, and (b) the qualifying change has an unallowable purpose. See section 212M for the meaning of “unallowable purpose”. (6) Condition D is that the main purpose, or one of the main purposes, of any arrangements is to procure that condition A or B or paragraph (a) of condition C is not met. (7) In this section— the amount of the relevant excess of allowances is the difference between RTWDV and BSV (see sections 212K and 212L); “ change arrangements ” and “ arrangements ” have the same meaning as in section 212M.