2.23 The Department determined that all the companies in Land Securities Trillium's corporate structure associated with the expanded PRIME contract are registered in the UK, and that it is operationally driven and not structured to deliberately avoid UK tax. The contract places certain restrictions on Land Securities Trillium's ability to transfer any property to an offshore entity:
■ the PRIME contractor and or any project associates cannot transfer any property to an offshore entity without the prior written consent of the department and no property is to be provided from a site owned by an offshore entity; and
■ the PRIME contractor or any project associates cannot transfer any properties to an offshore entity where the main purpose is to achieve a reduction in any UK tax that would otherwise be payable by the PRIME contractor.