For the assessment of corporation tax, no account shall be taken of a scheme or series of schemes which, having been put in place to obtain, as a principal objective or as one of the principal objectives, a tax advantage which runs counter to the object or purpose of the applicable tax law, are not genuine having regard to all the relevant facts and circumstances.
A scheme may comprise several stages or parts.
For the purposes of this Article, an arrangement or series of arrangements shall be regarded as not genuine to the extent that such arrangement or series of arrangements is not put in place for valid commercial reasons which reflect economic reality.
These provisions apply subject to those set out in III of Article 210-0 A.