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SCHEDULES

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

Loans made in a depreciating currencyU.K.

7(1)Paragraph 8 applies in relation to a loan where—U.K.

(a)the loan currency is a currency other than sterling, and

(b)it is reasonable to suppose that the main reason, or one of the main reasons, for the loan being made in that currency is that the loan currency is expected to depreciate as against sterling during the loan period.

(2)The “loan period”, in relation to a loan, is the period—

(a)beginning at the time the loan is made, and

(b)ending with the time by which, under the terms of the loan, the whole of the loan is to be repaid.