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SCHEDULEExcluded Arrangements

4.  The transfer constitutes a settlement.

In paragraph 1 reference to being “unconnected persons” is to be read in accordance with section 1122 of the Corporation Tax Act 2010(1).

In paragraph 2 reference to companies being “members of the same group of companies” is to be read in accordance with section 152 of the Corporation Tax Act 2010.

In paragraph 4 “settlement” has the meaning given by section 43 of the Inheritance Tax Act 1984(2).