SCHEDULES

SCHEDULE 16Penalties for enablers of defeated tax avoidance

PART 4Persons who “enabled” the arrangements

Persons who “enabled” the arrangements

7

1

A person is a person who “enabled” the arrangements mentioned in paragraph 1 if that person is—

a

a designer of the arrangements (see paragraph 8),

b

a manager of the arrangements (see paragraph 9),

c

a person who marketed the arrangements to T (see paragraph 10),

d

an enabling participant in the arrangements (see paragraph 11), or

e

a financial enabler in relation to the arrangements (see paragraph 12).

2

This paragraph is subject to paragraph 13 (excluded persons).