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ConceptUKReviewed October 2026
A UK rule that lets HMRC counteract tax arrangements it regards as abusive, taxing them on a just and reasonable basis rather than as the taxpayer set them up. It is a backstop that sits behind the specific, targeted anti-avoidance rules.
Introduced by the Finance Act 2013, it applies a double-reasonableness test, biting only on arrangements that cannot reasonably be regarded as a reasonable course of action.
A definition of an established legal or tax concept for general information. It is not advice on any individual situation.
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