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SCHEDULES

SCHEDULE 18Serial tax avoidance

PART 6Corporate groups, associated persons and partnerships

Representative member of a VAT group

45(1)Where a body corporate (“R”) is the representative member of a group (and accordingly is treated for the purposes of this Schedule as mentioned in section 43(1) of VATA 1994), anything which has been done by or in relation to another body corporate (“B”) in B’s capacity as representative member of that group is treated for the purposes of this Schedule as having been done by or in relation to R in R’s capacity as representative member of the group.

Accordingly paragraph 3 (warning period) operates as if the successive representative members of a group were a single person.

(2)This Schedule has effect as if the representative member of a group, so far as acting in its capacity as such, were a different person from that body corporate so far as acting in any other capacity.

(3)In this paragraph the reference to a “group” is to be interpreted in accordance with sections 43A to 43D of VATA 1994.