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SCHEDULES

SCHEDULE 5Tax treatment of financing costs and income

8In Chapter 6 (tax avoidance), before section 306 insert—

305ASchemes preventing this Part applying to a large group

(1)This section applies in relation to a period of account of a large group of entities if, apart from this section, this Part would not apply in relation to that period because of a failure by the group to meet the requirement of section 337(1)(b) (the worldwide group must contain one or more relevant group companies) throughout that period.

(2)If conditions A and B are met, this Part applies to the group as it would have applied had the scheme mentioned in condition A not been entered into.

(3)Condition A is that—

(a)at or before the end of the period of account, a scheme is entered into, and

(b)the main purpose, or one of the main purposes, for which a person becomes or is party to the scheme is to secure that the requirement of section 337(1)(b) is not met by the group throughout that period.

(4)Condition B is that the scheme is not an excluded scheme.