Part 7 of the Taxation (International and Other Provisions) Act 2010 (“TIOPA”) makes provisions relating to the treatment of certain financing costs and financing expenses of companies that are members of a group for the purposes of corporation tax. Chapter 6 of that Part makes anti-avoidance provisions in relation to schemes which manipulate those provisions, these Regulations specify certain types of scheme (“excluded schemes”) which are excluded from those anti-avoidance provisions.