SCHEDULES

SCHEDULE 18Serial tax avoidance

PART 5Penalty

Value of counteracted advantage: deferred tax

34

(1)

To the extent that the counteracted advantage (see paragraph 35) is a deferral of tax (other than VAT), the value of that advantage is—

(a)

25% of the amount of the deferred tax for each year of the deferral, or

(b)

a percentage of the amount of the deferred tax, for each separate period of deferral of less than a year, equating to 25% per year,

or, if less, 100% of the amount of the deferred tax.

(2)

This paragraph does not apply to a case to the extent that paragraph 33 applies.