“Limiting conditions
‘(1) The qualifying change meets one of the limiting conditions if condition A, B, C or D is met.
(2) Condition A is that the amount of the relevant excess of allowances is £50 million or more.
(3) Condition B is that the amount of the relevant excess of allowances—
(a) is £2 million or more but less than £50 million, and
(b) is not insignificant as a proportion of the total amount or value of the benefits derived by any relevant person by virtue of the qualifying change or change arrangements.
(4) “Relevant person” means a person who, at the end of the relevant day, is—
(a) a principal company of C,
(b) a person carrying on the relevant activity in partnership, or
(c) a person who is connected to a person within paragraph (a) or (b) (within the meaning of section 1122 of CTA 2010).
(5) Condition C is that—
(a) the amount of the relevant excess of allowances is less than £2 million, and
(b) the qualifying change has an unallowable purpose.