SCHEDULES

SCHEDULE 16 U.K. Penalties for enablers of defeated tax avoidance

PART 4 U.K. Persons who “enabled” the arrangements

Marketers of arrangements U.K.

10 U.K. For the purposes of paragraph 7 a person “marketed” the arrangements to T if, in the course of a business carried on by that person—

(a) that person made available for implementation by T a proposal which has since been implemented, in relation to T, by the arrangements, or

(b) that person—

(i) communicated information to T or another person about a proposal which has since been implemented, in relation to T, by the arrangements, and

(ii) did so with a view to T entering into the arrangements or transactions forming part of the arrangements.