Sch 4 para 11
In this Schedule— “ arrangements ” includes any scheme, agreement, understanding, transaction or series of transactions (whether or not legally enforceable), “ authorised investment fund ” means— an open-ended investment company within the meaning of section 613 of CTA 2010, or an authorised unit trust within the meaning of section 616 of that Act, “ business ” includes any trade, profession or vocation, “ employer ” has the same meaning as in Part 4 of FA 2004 (see section 279(1) of that Act), “ genuine diversity of ownership condition ” means— in the case of an offshore fund, the genuine diversity of ownership condition in regulation 75 of the Offshore Funds (Tax) Regulations 2009 (S.I. 2009/3001), and in the case of an authorised investment fund, the genuine diversity of ownership condition in regulation 9A of the Authorised Investment Fund (Tax) Regulations 2006 (S.I. 2006/964), “ material provision ” has the same meaning as in paragraph 2, “ non-UK tax ” has the meaning given by section 187 of CTA 2010, “ offshore fund ” has the same meaning as in section 354 of TIOPA 2010 (see section 355 of that Act), “ the overseas party ” has the meaning given by paragraph 1(2), “ overseas pension scheme ” has the same meaning as in Part 4 of FA 2004 (see section 150(7) of that Act), “ participator ” has the same meaning as in Part 10 of CTA 2010 (see section 454 of that Act), “ partnership ” includes an entity established under the law of a country or territory outside the United Kingdom of a similar character to a partnership, and “member” of a partnership is to be construed accordingly, “related individual” and “the resident party” have the meanings given by paragraph 1(2), “ tax advantage ” includes— relief or increased relief from income tax or corporation tax, repayment or increased repayment of income tax or corporation tax, avoidance or reduction of a charge or an assessment to income tax or corporation tax, avoidance of a possible assessment to income tax or corporation tax, deferral of a payment of tax or advancement of a repayment of tax, and avoidance of an obligation to deduct or account for tax, “ tax period ” has the meaning given by paragraph 5(7), “ the tax reduction ” has the meaning given by paragraph 5(2), and “ trust ” includes arrangements— which have effect under the law of a country or territory outside the United Kingdom, and under which persons acting in a fiduciary capacity hold and administer property on behalf of other persons, and “ beneficiaries ”, in relation to such arrangements, is to be construed accordingly.