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SCHEDULES

Section 81.

SCHEDULE 4U.K. Transfer to the Post Office company: tax

Corporation tax: generalU.K.

1U.K.The Post Office company shall, on and after the appointed day, be treated for all purposes of corporation tax as if it were the same person as the Post Office.

Shares and other securitiesU.K.

2U.K.Any share issued by the Post Office company or any of its wholly owned subsidiaries in pursuance of section 63 shall be treated for the purposes of the Corporation Tax Acts as if it had been issued wholly in consideration of a subscription paid to the company concerned of an amount equal to the nominal value of the share.

3U.K.Any security (other than a share) issued by the Post Office company or any of its wholly owned subsidiaries in pursuance of section 63 or 74 shall be treated for the purposes of the Corporation Tax Acts as if it had been issued wholly in consideration of a loan made to the company concerned of an amount equal to the principal sum payable under the security.

DebtU.K.

4U.K.Any debt assumed by the Post Office company under section 74(1) shall be treated for the purposes of the Corporation Tax Acts as if it had been assumed wholly in consideration of a loan made to the company of an amount equal to the principal sum payable under the debt.

Transfer arrangementsU.K.

5U.K.The existence or exercise of the powers of the Secretary of State under section 62 shall not be regarded as constituting or creating arrangements within the meaning of section 410 of the M1Income and Corporation Taxes Act 1988 (arrangements for the transfer of a company to another group or consortium).

Marginal Citations

Tax-free benefitsU.K.

6U.K.Nothing in this Part and nothing done under it shall be regarded as a scheme or arrangement for the purposes of section 30 of the M2Taxation of Chargeable Gains Act 1992 (tax-free benefits).

Marginal Citations

Assets acquired by the Post Office in 1969U.K.

7U.K.The Act of 1992 shall apply in relation to a disposal by the Post Office company of an asset acquired by the Post Office by virtue of Part III of the M3Post Office Act 1969 as if the acquisition or provision of the asset by the Crown had been the acquisition or provision of it by the Post Office company.

Marginal Citations

Value added taxU.K.

8U.K.The Post Office company shall, on and after the appointed day, be treated for all purposes of value added tax as if it were the same person as the Post Office.

Stamp dutyU.K.

9U.K.No transfer effected by virtue of section 62 shall give rise to any liability to stamp duty.