SCHEDULES

SCHEDULE 18U.K.Serial tax avoidance

PART 6U.K.Corporate groups, associated persons and partnerships

Partnership returns to which this paragraph appliesU.K.

50(1)This paragraph applies in relation to a partnership return if—U.K.

(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).