SCHEDULES

SCHEDULE 4U.K.Avoidance involving profit fragmentation arrangements

Reimbursement payments ignored for tax purposesU.K.

9U.K.In calculating income, profits or losses for any tax purposes, no account is to be taken of any amount which is paid (directly or indirectly) by a person for the purposes of meeting or reimbursing the cost of tax charged on the resident party by virtue of the application of paragraph 7.