Finance Act 2021

8 After section 212A insert—

“212B Penalty: partnerships

(1) This section applies if, in respect of a partnership—

(a) the responsible partner has been given a notice under—

(i) paragraph 12 of Schedule 43,

(ii) paragraph 8 or 9 of Schedule 43A, or

(iii) paragraph 8 of Schedule 43B,

stating that a tax advantage is to be counteracted, and

(b) the tax advantage, so far as arising to a partner (P) in the partnership, has been counteracted by the making of adjustments under section 209.

(2) P is liable to pay a penalty of an amount equal to 60% of the value of the counteracted tax advantage.

(3) Schedule 43C—

(a) gives the meaning of “the value of the counteracted tax advantage”, and

(b) makes other provision in relation to penalties under this section.

(4) For the meaning of “the responsible partner” see paragraph 2 of Schedule 43D.”