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SCHEDULES

SCHEDULE 36Agreement between UK and Switzerland

PART 2The past

Interest, penalties etc

9(1)Where, by virtue of this Part, P ceases to be liable to tax on a qualifying amount, P also ceases to be liable to any ancillary charge directly connected with that amount.

(2)Where, by virtue of this Part, all or part of a one-off payment is treated as if it were a credit allowable against the tax due from P taking account of a qualifying amount, the credit may also be used to offset any ancillary charge directly connected with that amount.

(3)Sub-paragraph (4) applies in the case of a qualifying amount that is part only of—

(a)an amount of income on which income tax is charged,

(b)a chargeable gain,

(c)the value of property forming part of the value transferred by a chargeable transfer, or

(d)the value of a supply on which VAT is charged.

(4)The amount of any ancillary charge directly connected with that qualifying amount is determined by apportioning the ancillary charge directly connected with the income, gain or value on a just and reasonable basis.