1U.K.Where—
(a)a person (“T”) has entered into abusive tax arrangements, and
(b)T incurs a defeat in respect of the arrangements,
a penalty is payable by each person who enabled the arrangements.
2(1)Parts 2 to 4 of this Schedule define—U.K.
“abusive tax arrangements”;
a “defeat in respect of the arrangements”;
a “person who enabled the arrangements”.
(2)The other Parts of this Schedule make provision supplementing paragraph 1 as follows—
(a)Part 5 makes provision about the amount of a penalty;
(b)Parts 6 to 8 provide for the assessment of penalties, referrals to the GAAR Advisory Panel and appeals against assessments;
(c)Part 9 applies information and inspection powers, and makes provision about declarations relating to legally privileged communications;
(d)Part 10 confers power to publish details of persons who have incurred penalties;
(e)Parts 11 and 12 contain miscellaneous and general provisions.