397.2.1. A municipality is not entitled to all or part of a rebate under this subdivision, or to an input tax refund, in respect of property, following a transaction, or a series of transactions pertaining to the property if(1) the property is property in respect of which the municipality may claim a rebate under this subdivision after 31 December 2013;
(2) the property was held by the municipality before 1 January 2014; and
(3) it is reasonable to consider that one of the main reasons for the transaction or for the series of transactions was to allow the municipality to recover, directly or indirectly, all or part of the tax it paid before 1 January 2014.
For the purposes of this section, “transaction” includes an arrangement or event.