- Arrangement generally connotes involvement of more than one person

 

"[160]...He suggested that in the absence of an arrangement it was hard to see that PGPH could have an intention or expectation that funding would be provided. I disagree. In my view an intention or expectation is clearly capable of being formed unilaterally, whereas an arrangement generally connotes some plan or understanding involving more than one person. The legislation uses both concepts and I think that is intentional, because they are quite distinct. The definition of development financier includes someone who has entered into any “arrangement” to provide finance, indicating some understanding, agreement or plan to which another person or persons is or are party." (PGPG Limited v. HMRC [2017] UKFTT 782 (TC), Judge Falk)

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