Sch 5 para 49
(1) This paragraph applies if on or after 29 October 2018 a company enters into an arrangement the main purpose or one of the main purposes of which is to secure for any person a tax advantage related to the coming into force of this Schedule. (2) The tax advantage is to be counteracted by means of adjustments. (3) The adjustments may be made (whether by an officer of Revenue and Customs or the person who would obtain the tax advantage) by way of an assessment, the modification of an assessment, an amendment or disallowance of a claim, or otherwise. (4) In this paragraph— “ arrangement ” includes any agreement, understanding, scheme, transaction or series of transactions (whether or not legally enforceable), “ tax advantage ” has the meaning given by section 1139 of CTA 2010.