SCHEDULES

SCHEDULE 16Penalties for enablers of defeated tax avoidance

PART 4Persons who “enabled” the arrangements

Marketers of arrangements

10

For the purposes of paragraph 7 a person “marketed” the arrangements to T if, in the course of a business carried on by that person—

a

that person made available for implementation by T a proposal which has since been implemented, in relation to T, by the arrangements, or

b

that person—

i

communicated information to T or another person about a proposal which has since been implemented, in relation to T, by the arrangements, and

ii

did so with a view to T entering into the arrangements or transactions forming part of the arrangements.