11(1)The amendments made by this Schedule have effect in relation to a loss if it arises directly or indirectly in consequence of, or otherwise in connection with—U.K.
(a)arrangements which are entered into on or after 21 October 2009, or
(b)any transaction forming part of arrangements which is entered into on or after that date.
(2)But those amendments do not have effect where the arrangements are, or any such transaction is, entered into pursuant to an unconditional obligation in a contract made before that date.
(3)“An unconditional obligation” means an obligation which may not be varied or extinguished by the exercise of a right (whether or not under the contract).