(1)An impermissible avoidance arrangement means an arrangement, the main purpose of which is to obtain a tax benefit, and it—(a)creates rights, or obligations, which are not ordinarily created between persons dealing at arm's length;(b)results, directly or indirectly, in the misuse, or abuse, of the provisions of this Act;(c)lacks commercial substance or is deemed to lack commercial substance under section 180, in whole or in part; or(d)is entered into, or carried out, by means, or in a manner, which are not ordinarily employed for bona fide purposes.
