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SCHEDULES

SCHEDULE 21U.K.Penalties in connection with offshore asset moves

Amount of the penaltyU.K.

6(1)The penalty payable under paragraph 1(1) is 50% of the amount of the original penalty payable by P.U.K.

(2)The penalty payable under paragraph 1(1) is not a penalty determined by reference to a liability to tax (despite the fact that the original penalty by reference to which it is calculated may be such a penalty).