SCHEDULES
SCHEDULE 19Large businesses: tax strategies and sanctions
PART 3Sanctions for persistently unco-operative large businesses
Application of Part 3 to large companies
51
1
A UK company falls within this Part if—
a
the company has persistently engaged in unco-operative behaviour (see paragraphs 36 to 38),
b
some or all of the unco-operative behaviour has caused there to be, or contributed to there being, two or more significant tax issues in respect of the company which are unresolved (see paragraph 39), and
c
there is a reasonable likelihood of further instances of the company engaging in unco-operative behaviour in a manner which causes there to be, or contributes to there being, significant tax issues in respect of the company.
2
Paragraphs 36 to 39 apply in relation to a company as they apply in relation to a UK group.
3
Paragraphs 41 to 45 apply in relation to a company as they apply in relation to the head of a UK group.
4
As applied by this paragraph, paragraphs 36 to 39 and 41 to 45 have effect as if references to a UK group, the head of a UK group or a member of a UK group were references to a company.
5
Paragraph 47 applies in relation to a company as it applies in relation to a member of a group.
6
Paragraph 49 applies in relation to a company as it applies in relation to a group.
7
As applied by this paragraph, paragraphs 47 and 49 have effect as if references to a group, the head of a group or a member of a group were references to a company.