Summary
For the purposes of whether a share issue was classed as “disqualifying arrangements” by virtue of Condition A in the Income Tax Act 2007 s.178A, the words “party to” in s.178A(6) were to be interpreted as meaning that a person could be regarded as a party to arrangements falling within s.178A if they had sufficient involvement in them that it was appropriate to treat them as participating in the purpose of the share issue.