SCHEDULES
SCHEDULE 19Large businesses: tax strategies and sanctions
PART 3Sanctions for persistently unco-operative large businesses
36Large groups falling within Part 3
1
A UK group has “engaged in unco-operative behaviour” if—
a
a member of the group has satisfied either or both of the conditions listed in sub-paragraph (2), or
b
two or more of the members of the group, taken together, have satisfied either or both of those conditions.
2
Those conditions are—
a
the behaviour condition (see paragraph 37);
b
the arrangements condition (see paragraph 38).
3
A UK group has engaged in unco-operative behaviour “persistently” if—
a
a member of the group has done so persistently, or
b
two or more members of the group, taken together, have done so persistently.
4
References in this Part to doing something “persistently” include doing it on a sufficient number of occasions for it to be clear that it represents a pattern of behaviour.