SCHEDULE 1Persons who have significant influence or control over another

PART 5Overseas entities

Interpretation of Part 5

18.

(1)

For the purposes of paragraphs 19 and 23, “arrangement” includes—

(a)

any scheme, agreement or understanding, whether or not it is legally enforceable, and

(b)

any convention, custom or practice of any kind.

(2)

But something does not count as an arrangement unless there is at least some degree of stability about it (whether by its nature or terms, the time it has been in existence or otherwise).