Section 86N
Anti-avoidance
(1)
If —
(a)
a person enters into any arrangement or takes any action;
and
(b)
in the Collector’s view, the main purpose, or one of the main purposes of the person in entering into the arrangements or in taking the action is to avoid any obligation under, or to circumvent the application of section 86L or any regulation made under section 86Q, then the Collector may in writing direct a relevant person that section 86L or the regulation has effect in relation to the relevant person as if the arrangements had not been entered into or the action had not been taken, and section 86L or the regulation shall then apply accordingly.
(2)
In subsection (1), “relevant person” means a person who is subject to section 86L or the regulation, and whom the Collector considers should receive the direction.