SCHEDULES

SCHEDULE 16Penalties for enablers of defeated tax avoidance

PART 3“Defeat” in respect of abusive tax arrangements

“Defeat” in respect of abusive tax arrangements

4

T (within the meaning of paragraph 1) incurs a “defeat” in respect of abusive tax arrangements entered into by T (“the arrangements concerned”) if—

(a)

Condition A (in paragraph 5) is met, or

(b)

Condition B (in paragraph 6) is met.