Finance Act 2016 (c. 24)

SCHEDULES

SCHEDULE 19 U.K. Large businesses: tax strategies and sanctions

PART 2 U.K. Publication of tax strategies

Penalties under this Part: general provisions U.K.

26 (1) Paragraphs 27 to 33 apply in relation to the liability of any person to a penalty under this Part and, accordingly, in those paragraphs— U.K.

• “failure”, in relation to a liability for a penalty, means a failure which could give rise to that liability,

• “liability to a penalty” means a liability under paragraph 18, 21 or 24 (including paragraph 24 as applied to a qualifying UK partnership), and

• “penalty” means a penalty under any of those paragraphs.

(2) In those paragraphs “tribunal” means the First-tier Tribunal or, where determined by or under the Tribunal Procedure Rules, the Upper Tribunal.