SCHEDULES

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

Accelerated payments

19

1

Paragraph 20(1) applies where—

a

section 23E of ITTOIA 2005 would (ignoring paragraph 20) apply in relation to a relevant benefit arising to T,

b

the relevant benefit is a loan or quasi-loan in relation to which paragraph 1(2) applies,

c

an accelerated payment notice, or a partner payment notice, relating to a relevant charge (the “accelerated payment notice”) has been given under Chapter 3 of Part 4 of FA 2014,

d

T makes a payment (the “accelerated payment”) in respect of the understated or disputed tax to which the notice relates,

e

the accelerated payment is made on or before F15 April 2019, and

f

the amount of the loan or quasi-loan that, at the end of F25 April 2019, is outstanding for the purposes of paragraph 1 (see paragraphs 3 to 14) is equal to or less than the amount of the accelerated payment.

2

In sub-paragraph (1)(c), “relevant charge” means a charge to tax under section 23E of ITTOIA 2005 arising by reason of a relevant benefit which arises to T in pursuance of the relevant arrangement in pursuance of which the relevant benefit mentioned in sub-paragraph (1)(a) and (b) arises.

F33

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