SCHEDULES

SCHEDULE 3Sideways relief etc

Commencement

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—

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).