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SCHEDULES

SCHEDULE 4U.K.Avoidance involving profit fragmentation arrangements

CommencementU.K.

12U.K.This Schedule has effect—

(a)for income tax purposes, in relation to any value transferred on or after 6 April 2019 as a result of a material provision, and

(b)for corporation tax purposes, in relation to any value transferred on or after 1 April 2019 as a result of a material provision.