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SCHEDULES

SCHEDULE 12U.K.Trading income provided through third parties: loans etc outstanding on 5 April 2019

Meaning of “outstanding”: quasi-loans in currencies other than sterlingU.K.

10(1)Paragraphs 11 to 14 apply where P makes a quasi-loan to T by reason of acquiring a right to a payment in a particular currency (the “quasi-loan currency”).U.K.

(2)For the purposes of paragraphs 11 to 14, the value of an amount in a particular currency is to be determined by reference to an appropriate spot rate of exchange.

11(1)This paragraph applies in relation to the quasi-loan if the quasi-loan currency is a currency other than sterling.U.K.

(2)But this paragraph does not apply if paragraph 14 applies in relation to the quasi-loan.

(3)The amount of the quasi-loan that is outstanding, at the relevant time, is to be calculated in sterling as follows—

(4)For the purposes of this paragraph and paragraph 14, the “relevant time” in relation to a quasi-loan is the time immediately before the end of 5 April 2019.

(5)See paragraph 12 for provision about repayments made in a currency other than the quasi-loan currency.