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SCHEDULES

SCHEDULE 19U.K.Large businesses: tax strategies and sanctions

PART 1 U.K.Interpretation

“UK sub-group” and “head” (in relation to a UK sub-group)U.K.

11(1)A “UK sub-group” consists of two or more relevant bodies that would be a UK group, but for the fact that they are members of a larger group headed by a relevant body incorporated outside the United Kingdom.U.K.

(2)A UK sub-group is headed by the company or other relevant body incorporated in the United Kingdom that is not a 51% subsidiary of another member of the UK sub-group (and “head”, in relation to the sub-group, means that company or body).