SCHEDULES

SCHEDULE 19Large businesses: tax strategies and sanctions

PART 3Sanctions for persistently unco-operative large businesses

Large groups falling within Part 3

39

1

There is a significant tax issue in respect of a UK group or a member of a UK group where—

a

there is a disagreement between HMRC and a member of the group about an issue affecting the amount of the liability of the group or a member of the group to UK taxation,

b

the issue has been, or could be, referred to a court or tribunal to determine, and

c

as regards the amount of the liability, the difference between HMRC's view and the view of the member is, or is likely to be, not less than £2 million.

2

The reference in sub-paragraph (1)(a) to circumstances in which there is a disagreement include circumstances in which there is a reasonable likelihood of a disagreement.

3

The Treasury may by regulations substitute a higher amount for the amount for the time being specified in sub-paragraph (1)(c).