SCHEDULES

SCHEDULE 11Index of defined expressions used in Parts 2 to 8

Section 379

Part 1Double taxation relief: index of defined expressions used in Parts 2 and 3

the arrangements (in Chapter 2 of Part 2)

section 21(1)

chargeable gain (in Part 2 so far as relating to capital gains tax)

section 105

double taxation arrangements (in Part 2)

section 2(4)

double taxation arrangements (in Part 3)

section 136(2)

foreign tax (in Chapter 2 of Part 2)

section 21(1)

F1insurance company

section 65 of FA 2012 (as applied by section 141(2) of that Act)

international arrangements (in Part 3)

section 136(3)

F1long-term business

section 63 of FA 2012 (as applied by section 141(2) of that Act)

the non-UK territory (in Chapter 2 of Part 2)

section 21(1)

the Savings Directive (in Part 3)

section 136(4)

savings income (in Part 3)

section 136(5)

special withholding tax (in Part 3)

section 136(6)

tax not chargeable directly or by deduction (in Chapter 2 of Part 2)

sections 17(3) and 20(4)

tax payable or chargeable (in Chapter 2 of Part 2)

sections 17(3) and 20(4)

tax payable or paid under the law of a territory outside the United Kingdom (in Chapter 2 of Part 2, except section 29, in its application to relief under unilateral relief arrangements)

section 8(2)

underlying tax (in Chapter 2 of Part 2)

section 21(1)

unilateral relief arrangements (in Part 2)

section 8(1)

Part 2Transfer pricing: index of defined expressions used in Part 4

the actual provision (in Part 4)

section 149

the advantaged person (in Chapter 4 of Part 4)

section 174(1)

the affected persons (in Part 4)

section 149(1), (2)

the arm's length provision (in Part 4)

section 151

control (of a body corporate or firm) (in Part 4)

section 217

the disadvantaged person (in Chapter 4 of Part 4)

section 174(1)

firm (in Part 4)

section 217(8)

the guarantor company (in Chapter 5 of Part 4)

section 191(5)

the issuing company (in Chapter 5 of Part 4)

section 191(5)

losses (in Part 4)

section 156(1)

medium-sized enterprise (in Chapter 3 of Part 4)

section 172

participation (direct or indirect) in the management, control or capital of another person (in Part 4)

Chapter 2 of Part 4

potential advantage in relation to United Kingdom taxation (in Part 4)

section 155(2)

profits (in Part 4)

section 156(2)

the relevant activities (in Part 4)

section 216

relevant notice (in Chapter 4 of Part 4)

section 190

section 182 claim (in Part 4)

section 181(3)

the security (in Chapter 5 of Part 4)

section 191(5)

small enterprise (in Chapter 3 of Part 4)

section 172

transaction, and series of transactions (in Part 4)

section 150

transfer pricing notice (in Chapter 3 of Part 4)

section 168(2)

Part 3Advance pricing agreements: index of defined expressions used in Part 5

advance pricing agreement (in Part 5)

section 218(1)

the Commissioners (in Part 5)

section 230

officer (in Part 5)

section 230

F2Part 4Tax arbitrage: index of defined expressions used in Part 6

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

F3PART 4AHybrid and other mismatches: index of defined expressions used in Part 6A

arrangement (in Part 6A)

section 259NF

CFC and CFC charge (in Part 6A)

section 259B(4)

the Commissioners (in Part 6A)

section 259NF

control group (in Part 6A)

section 259NB

deduction period (in Chapter 10 of Part 6A)

section 259JA(5)(a)

dual resident company (in Chapter 10 of Part 6A)

section 259JA(3)

dual territory double deduction amount (in Chapter 10 of Part 6A)

section 259JA(5)

dual territory double deduction (in Chapter 11 of Part 6A)

section 259KB

excessive PE deduction (in Chapter 6 of Part 6A)

section 259FA(8)

excessive PE deduction (in Chapter 11 of Part 6A)

section 259KB

financial instrument (in Part 6A)

section 259N

foreign CFC and foreign CFC charge (in Part 6A)

section 259B(4)

foreign deduction period (in Chapter 10 of Part 6A)

section 259JA(5)(b)

hybrid entity (in Part 6A)

section 259BE

hybrid entity deduction period (in Chapter 9 of Part 6A)

section 259IA(2)(a)

hybrid entity double deduction amount (in Chapter 9 of Part 6A)

section 259IA(4)

hybrid or otherwise impermissible deduction/non-inclusion mismatch (in Chapter 3 of Part 6A)

section 259CB

hybrid payee (in Chapter 7 of Part 6A)

section 259GA(3)

hybrid payee deduction/non-inclusion mismatch (in Chapter 7 of Part 6A)

section 259GB

hybrid payer (in Chapter 5 of Part 6A)

section 259EA(3)

hybrid payer deduction/non-inclusion mismatch (in Chapter 5 of Part 6A)

section 259EB

hybrid transfer arrangement (in Chapter 4 of Part 6A)

section 259DB

hybrid transfer deduction/non-inclusion mismatch (in Chapter 4 of Part 6A)

section 259DC

imported mismatch payment (in Chapter 11 of Part 6A)

section 259KA(2)

imported mismatch arrangement (in Chapter 11 of Part 6A)

section 259KA(2)

investor (in Part 6A)

section 259BE(4)

investor deduction period (in Chapter 9 of Part 6A)

section 259IA(2)(b)

investor jurisdiction (in Part 6A)

section 259BE(4)

mismatch payment (in Chapter 11 of Part 6A)

section 259KA(6)

multinational company (in Chapter 6 of Part 6A)

section 259FA(3)

multinational company (in Chapter 8 of Part 6A)

section 259HA(4)

multinational payee deduction/non-inclusion mismatch (in Chapter 8 of Part 6A)

section 259HB

ordinary income (in Part 6A)

sections 259BC and 259BD

over-arching arrangement (in Chapter 11 of Part 6A)

section 259KA(5)

P (in Chapter 11 of Part 6A)

section 259KA(3)

parent jurisdiction (in Chapter 6 of Part 6A)

section 259FA(3)(a)

parent jurisdiction (in Chapter 8 of Part 6A)

section 259HA(4)(a)

parent jurisdiction (in Chapter 10 of Part 6A)

section 259JA(4)(b)(ii)

payee (in Part 6A)

section 259BB(6)

payee jurisdiction (in Part 6A)

section 259BB(9)

payer (in Part 6A)

section 259BB(1)(a) or (2)

payment (in Part 6A)

section 259BB(1)

payment period (in Part 6A)

section 259BB(1)(b) or (2)

PE jurisdiction (in Chapter 8 of Part 6A)

section 259HA(4)(b)

PE jurisdiction (in Chapter 10 of Part 6A)

section 259JA(4)(a)

PE jurisdiction (in Chapter 11 of Part 6A)

section 259KB(3)(a)

permanent establishment (in Part 6A)

section 259BF

quasi-payment (in Part 6A)

section 259BB(2) to (5)

related (in Part 6A)

section 259NC

relevant deduction (in Part 6A)

section 259BB(1)(b) or (2)(a)

relevant investment fund (in Part 6A)

section 259NA

relevant mismatch (in Chapter 11 of Part 6A)

section 259KA(6)

relevant multinational company (in Chapter 10 of Part 6A)

section 259JA(4)

relevant PE period (in Chapter 6 of Part 6A)

section 259FA(4)

series of arrangements (in Chapter 11 of Part 6A)

section 259KA(5)

substitute payment (in Chapter 4 of Part 6A)

section 259DB(5)

tax (in Part 6A)

section 259B

taxable period (in Part 6A)

section 259NF

taxable profits (in Part 6A)

sections 259BC(2) and 259BD(5)

underlying instrument (in Chapter 4 of Part 6A)

section 259DB(3)

underlying return (in Chapter 4 of Part 6A)

section 259DB(5)(b)

F4Part 5Tax treatment of financing costs and income: index of defined expressions used in Part 7

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Part 6Offshore funds: index of defined expressions used in Part 8

participant (in Part 8)

section 362(1)

participation (in Part 8)

section 362(2)

part of umbrella arrangements (in Part 8)

section 363(2)

umbrella arrangements (in Part 8)

section 363(1)

F5PART 7Corporate interest restriction: index of defined expressions used in Part 10

abbreviated interest restriction return (in Part 10)

paragraph 20 of Schedule 7A

abbreviated return election (in Part 10)

paragraph 19 of Schedule 7A

accounting period (in Part 10)

Chapter 2 of Part 2 of CTA 2009 (applied by section 1119 of CTA 2010)

adjusted net group-interest expense of a worldwide group (in Part 10)

section 413

aggregate net tax-interest expense of a worldwide group (in Part 10)

section 390

aggregate net tax-interest income of a worldwide group (in Part 10)

section 390

aggregate tax-EBITDA of a worldwide group (in Part 10)

section 405

allocated reactivation of company for period of account (in Part 10)

paragraph 25 of Schedule 7A

allowable loss (in Part 10)

TCGA 1992 (applied by section 1119 of CTA 2010)

associated (in Chapter 8 of Part 10)

section 449(2)

amount available for reactivation of company in period of account (in Part 10)

paragraph 26 of Schedule 7A

available, in relation to interest allowance (in Chapter 4 of Part 10)

section 393

balance sheet (in Chapter 8 of Part 10)

section 449(1)

chargeable gain (in Part 10)

TCGA 1992 (applied by section 1119 of CTA 2010)

the Commissioners (in Part 10)

section 494(1)

company (in Part 10)

section 1121 of CTA 2010

company tax return (in Schedule 7A)

paragraph 73 of Schedule 7A

consenting company (in Part 10)

paragraph 10 of Schedule 7A

consolidated partnership (in Part 10)

section 430

consolidated subsidiary of another entity (in Part 10)

section 475

derivative contract (in Part 10)

Part 7 of CTA 2009 (applied by section 1119 of CTA 2010)

disallowed, in relation to tax-interest expense amount (in Part 10)

section 378

drawn up on acceptable principles, in relation to financial statements (in Chapter 11 of Part 10)

section 481

fair value accounting (in Part 10)

section 494(1)

fair value (in Part 10)

section 494(1)

filing date, in relation to a period of account of a worldwide group (in Part 10)

paragraph 7(5) of Schedule 7A

finance lease (in Part 10)

section 494(1)

financial asset (in Chapter 8 of Part 10)

section 449(1)

financial statements of a worldwide group (in Part 10)

section 479

fixed ratio method (in Part 10)

section 397

for accounting purposes (in Part 10)

section 1127(4) of CTA 2010

full interest restriction return (in Part 10)

paragraph 20 of Schedule 7A

generally accepted accounting practice (in Part 10)

section 1127(1) and (3) of CTA 2010

group-EBITDA (chargeable gains) election (in Part 10)

paragraph 15 of Schedule 7A

group ratio election (in Part 10)

paragraph 13 of Schedule 7A

group ratio (blended) election (in Part 10)

paragraph 14 of Schedule 7A

group ratio method (in Part 10)

section 398

group ratio percentage (in Part 10)

section 399

IAS financial statements (in Part 10)

section 488

impairment loss (in Part 10)

section 391

income (in Part 10)

section 1119 of CTA 2010

insurance company (in Part 10)

section 141 of FA 2012

interest allowance of a worldwide group (in Part 10)

section 396

interest allowance (alternative calculation) election (in Part 10)

paragraph 16 of Schedule 7A

interest allowance (consolidated partnerships) election (in Part 10)

paragraph 18 of Schedule 7A

interest allowance (non-consolidated investment) election (in Part 10)

paragraph 17 of Schedule 7A

interest capacity of a worldwide group (in Part 10)

section 392

interest reactivation cap of a worldwide group (in Part 10)

section 373

interest restriction return (in Part 10)

section 494(1)

international accounting standards (in Part 10)

section 1127(5) of CTA 2010

investor in a worldwide group (in Part 10)

section 404

loan relationship (in Part 10)

Part 5 of CTA 2009 (applied by section 1119 of CTA 2010)

loan relationships or other financing arrangements (in Chapter 8 of Part 10)

section 449(1)

local authority (in Part 10)

section 1130 of CTA 2010

local authority association (in Part 10)

section 1131 of CTA 2010

member of a worldwide group (in Part 10)

section 473(4)(a)

multi-company worldwide group (in Part 10)

section 473(4)(d)

net group-interest expense of a worldwide group (in Part 10)

section 410

net tax-interest expense of a company (in Part 10)

section 389

net tax-interest income of a company (in Part 10)

section 389

non-consenting company (in Part 10)

paragraph 10 of Schedule 7A

non-consolidated associate of a worldwide group (in Part 10)

section 429

non-consolidated subsidiary of an entity (in Part 10)

section 475

notice (in Part 10)

section 1119 of CTA 2010

party to a loan relationship (in Part 10)

section 494(2)

F6pension scheme (in Part 10)

section 494(1)

period of account of a worldwide group (in Part 10)

section 480

profit before tax, of a worldwide group (in Chapter 7 of Part 10)

section 416

pro-rata share of company (of total disallowed amount) (in Part 10)

paragraph 23 of Schedule 7A

pro-rata share of accounting period (of total disallowed amount) (in Part 10)

paragraph 24 of Schedule 7A

provision (in relation to a public infrastructure asset) (in Chapter 8 of Part 10)

section 436

public infrastructure asset (in Chapter 8 of Part 10)

section 436

qualifying charitable donation (in Part 10)

Part 6 of CTA 2010 (applied by section 1119 of CTA 2010)

qualifying infrastructure company (in Chapter 8 of Part 10)

section 433

qualifying infrastructure activity (in Chapter 8 of Part 10)

section 436

qualifying net group-interest expense of a worldwide group (in Part 10)

section 414

recognised, in financial statements (in Part 10)

section 489

recognised stock exchange (in Part 10)

section 1137 of CTA 2010

registered pension scheme (in Part 10)

section 150(2) of FA 2004 (applied by section 1119 of CTA 2010)

related party (in Part 10)

sections 462 to 472

related party investor (in Part 10)

section 404

relevant asset (in Chapter 7 of Part 10)

section 417

relevant accounting period (in Part 10)

section 490

relevant expense amount (in Chapter 7 of Part 10)

section 411

relevant income amount (in Chapter 7 of Part 10)

section 411

relevant public body (in Part 10)

section 491

reporting company (in Part 10)

section 494(1)

the return period (in Part 10)

section 494(1)

service concession agreement (in Part 10)

section 494(1)

share, of an investor in a worldwide group (in Part 10)

section 404

single-company worldwide group (in Part 10)

section 473(4)(c)

subject to interest reactivations (in Part 10)

section 373

subject to interest restrictions (in Part 10)

section 373

tax (in Part 10)

section 1119 of CTA 2010

tax-EBITDA of a company (in Part 10)

section 406

tax-interest expense amount of a company (in Part 10)

section 382

tax-interest income amount of a company (in Part 10)

section 385

trade (in Part 10)

section 1119 of CTA 2010

total disallowed amount of a worldwide group (in Part 10)

section 373

UK generally accepted accounting practice (in Part 10)

section 1127(2) of CTA 2010

UK group company (in Part 10)

section 492

UK property business (in Part 10)

Chapter 2 of Part 4 of CTA 2009 (applied by section 1119 of CTA 2010)

the UK sector of the continental shelf (in Chapter 8 of Part 10)

section 449(1)

the ultimate parent, of a worldwide group (in Part 10)

section 473(4)(b)

unexpired (in Chapter 4 of Part 10)

section 395

United Kingdom (in Part 10)

section 1170 of CTA 2010

used (in Chapter 4 of Part 10)

section 394

within the charge to corporation tax (in Part 10)

section 1167 of CTA 2010

wholly-owned subsidiary (in Part 10)

section 494(1)

a worldwide group (in Part 10)

section 473