SCHEDULES
C1SCHEDULE 18Serial tax avoidance
PART 6Corporate groups, associated persons and partnerships
Partnership returns to which this paragraph applies
50
1
This paragraph applies in relation to a partnership return if—
a
that return has been made on the basis that a tax advantage arises to a partner from any arrangements, and
b
that person has incurred, in relation to that tax advantage and those arrangements, a relevant defeat by virtue of Condition A (final counteraction of tax advantage under general anti-abuse rule).
2
Where a person has incurred a relevant defeat by virtue of sub-paragraph (2) of paragraph 13 (Condition B: case involving partnership follower notice) this paragraph applies in relation to the partnership return mentioned in that sub-paragraph.
3
This paragraph applies in relation to a partnership return if—
a
that return has been made on the basis that a tax advantage arises to a partner from any arrangements, and
b
that person has incurred, in relation to that tax advantage and those arrangements, a relevant defeat by virtue of Condition C (return, claim or election made in reliance on DOTAS arrangements).
4
The references in this paragraph to a relevant defeat do not include a relevant defeat incurred by virtue of paragraph 47(2).
Sch. 18 modified (17.12.2020 for specified purposes, 31.12.2020 in so far as not already in force) by 1994 c. 23, Sch. 9ZA para. 79 (as inserted by Taxation (Post-transition Period) Act 2020 (c. 26), s. 11(1)(e), Sch. 2 para. 2 (with s. 3(4), Sch. 2 para. 7(7)-(10)); S.I. 2020/1642, reg. 9)