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SCHEDULES

SCHEDULE 3U.K.Qualifying scheme

Part 3 U.K.Schemes involving hybrid effect

Debt instruments treated as equityU.K.

8(1)A scheme satisfies the requirements of this paragraph if it includes a debt instrument issued by a company that is treated as equity in the company under generally accepted accounting practice.U.K.

(2)For the purposes of this paragraph, a debt instrument is an instrument issued by a company that represents a loan relationship of the company or, if the company were a company resident in the United Kingdom, would represent a loan relationship of the company.