11 Loss schemes — individuals

This Regulation applies to a transaction where the promoter expects more than one individual to implement the same, or substantially the same, transaction and the transaction is such that an informed observer, having examined it, could reasonably conclude—

(a) that a main outcome of the transaction that could be expected for some or all of the individuals participating in it is the provision of losses, and

(b) that those individuals would be expected to use such losses to reduce their liability to income tax or capital gains tax.