Schedule 2 - Employment income provided through third parties

Part of Finance (No. 3) Bill – in a Public Bill Committee at 3:15 pm on 19th May 2011.

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Amendments made: 102, page 54, line 6 [Schedule 2], leave out ‘Subject to section 554B(5), in’ and insert ‘In’.

103, page 55, line 21 [Schedule 2], leave out from beginning to end of line 8 on page 56.

10, page 56, line 35 [Schedule 2], after ‘420’ insert ‘for the purposes of Chapters 1 to 5 of Part 7’.

11, page 58 [Schedule 2], leave out lines 35 to 38.

12, page 59, line 15 [Schedule 2], leave out from beginning to end of line 44 and insert—

“(2) Subject to subsection (4), subsection (3) applies to a relevant step taken by a person (“P”) if—

(a) the relevant step is not taken under an arrangement mentioned in subsection (1)(a) to (c), and

(b) there is no connection (direct or indirect) between the relevant step and a tax avoidance arrangement.

(3) Chapter 2 does not apply by reason of the relevant step if the step is taken solely for the purpose of—

(a) acquiring or holding shares—

(i) to be awarded under an approved SIP, or

(ii) to be provided pursuant to options granted under an approved SAYE option scheme or an approved CSOP scheme, or

(b) providing shares pursuant to—

(i) an award of shares under an approved SIP, or

(ii) an option granted under an approved SAYE option scheme or an approved CSOP scheme.

(5) Subsection (3) does not apply to the relevant step if, immediately before or after the step is taken—

(a) the total number of shares of any type held, in relation to the approved SIP, the approved SAYE option scheme or the approved CSOP scheme, by P and any other persons for purposes within subsection (3)(a) and (b), exceeds

(b) the maximum number of shares of that type which might reasonably be expected to be required, in relation to the approved SIP, the approved SAYE option scheme or the approved CSOP scheme, for those purposes over the period of ten years starting with the day on which the relevant step is taken.’.

13, page 59, line 46 [Schedule 2], leave out ‘, 8 or 9’ and insert ‘or 8’.

14, page 59, line 46 [Schedule 2], at end insert—

“(5A) Chapter 2 does not apply by reason of a relevant step taken by a person (“P”) if—

(a) the relevant step is taken for the sole purpose of—

(i) granting qualifying options under an EMI arrangement,

(ii) acquiring or holding shares to be provided pursuant to qualifying options granted under an EMI arrangement, or

(iii) providing shares pursuant to qualifying options granted under an EMI arrangement, and

(b) there is no connection (direct or indirect) between the relevant step and a tax avoidance arrangement.

(5B) But subsection (5A) does not apply to the relevant step if, immediately before or after the step is taken—

(a) the total number of shares of any type held, in relation to the EMI arrangement, by P and any other persons for purposes within subsection (5A)(a)(i) to (iii), exceeds

(b) the maximum number of shares of that type which might reasonably be expected to be required, in relation to the EMI arrangement, for those purposes over the period of ten years starting with the day on which the relevant step is taken.

(5C) In subsections (5A) and (5B) “EMI arrangement” means an arrangement under which qualifying options are granted.

(5D) Terms used in subsections (5A) to (5C) have the same meaning as in Chapter 9 of Part 7.’.

15, page 60, line 3 [Schedule 2], leave out ‘(1)(e)’ and insert ‘(3) or (5A)’.

16, page 60, line 6 [Schedule 2], leave out from ‘for’ to ‘but’ in line 7 and insert ‘purposes within subsection (3)(a) and (b) or (5A)(a)(i) to (iii),’.

17, page 62, line 27 [Schedule 2], leave out ‘B awards A’ and insert ‘A is awarded’.

18, page 62, line 34 [Schedule 2], leave out from ‘terms”)’ to first ‘the’ in line 38 and insert ‘the main purpose of which is to defer the provision to A of the deferred remuneration to a specified date (“the vesting date”) which is after the award date, while providing that’.

19, page 63 [Schedule 2], leave out lines 11 to 15.

20, page 63, line 16 [Schedule 2], leave out ‘mentioned in subsection (1)(c)(ii)’ and insert ‘relating to revocation required by subsection (1)(c)’.

21, page 64, line 26 [Schedule 2], leave out from ‘terms’ to end of line 42.

22, page 65, line 9 [Schedule 2], leave out ‘shares’ and insert ‘certain shares or securities’.

23, page 65, line 10 [Schedule 2], leave out ‘shares’ and insert ‘certain shares or securities’.

24, page 65, line 11 [Schedule 2], leave out ‘Section 554L is’ and insert ‘Sections 554L and 554LA are’.

25, page 65, line 12 [Schedule 2], leave out ‘shares’ and insert ‘certain shares or securities’.

26, page 65, line 13 [Schedule 2], leave out ‘shares’ and insert ‘certain shares or securities’.

27, page 65, line 14 [Schedule 2], leave out ‘554L’ and insert ‘554LA’.

28, page 65, line 17 [Schedule 2], leave out from ‘393B(2)(a),’ to end of line 22 and insert—

‘“relevant shares” means—

(a) shares (including stock) in B,

(b) instruments issued by B which are securities for the purposes of Chapters 1 to 5 of Part 7 within section 420(1)(b), or

(c) units in a collective investment scheme (as defined in section 420(2)) managed by B which are securities for the purposes of Chapters 1 to 5 of Part 7 within section 420(1)(e), and

“trading company” means a company the business of which consists wholly or mainly in the carrying on of a trade.

(5) If B is a member of a group of companies, in the definition of “relevant shares” in subsection (4) references to B are to be read as including references to any other company which is a member of that group.

(6) For the purposes of sections 554K and 554LA an exit event occurs if—

(a) shares in the relevant company are admitted to trading on a stock exchange,

(b) all the shares in the relevant company, or a substantial proportion of them, are disposed of to persons none of whom are connected with any of the persons making any disposal,

(c) if the relevant company is a trading company (as defined in subsection (4)), the company’s trade, or a substantial proportion of it, is transferred to a person who is not a relevant connected person,

(d) the relevant company’s assets, or a substantial proportion of them, are disposed of to a person who is not a relevant connected person,

(e) the winding up of the relevant company starts, or

(f) a person (“P”) who controls the relevant company ceases to control it, so long as no person connected with P starts to control it.

(7) For the purposes of subsection (6)—

(a) “the relevant company” means—

(i) if the relevant shares mentioned in section 554K(1)(a)(i) or (ii) or 554LA(1)(a)(i) or (ii) are shares (including stock), the company in which they are shares, or

(ii) if the relevant shares so mentioned are instruments within paragraph (b) of the definition of “relevant shares” in subsection (4), the company by which those instruments are issued,

(b) “relevant connected person” means a person who—

(i) is connected with the relevant company, or

(ii) is a shareholder in the relevant company or is connected with a shareholder in the relevant company,

(c) the relevant company’s trade, or a substantial proportion of it, is transferred to another person if—

(i) the relevant company ceases to carry on the trade or the proportion of it, and

(ii) on that occurring, the other person starts to carry on the trade or the proportion of it, and

(d) section 12(7) of CTA 2009 applies for the purpose of determining when the winding up of the relevant company starts.’.

29, page 65, line 26 [Schedule 2], leave out ‘B may make to A an award’ and insert ‘an award may be made to A’.

30, page 65, line 35 [Schedule 2], leave out from ‘terms”)’ to ‘the’ in line 41 and insert ‘the main purpose of which is to defer the receipt of the shares by A, or the payment of the sum of money to A, to a specified date (“the vesting date”) which is after the date (“the award date”) on which the award is made, while providing that’.

31, page 65, line 43 [Schedule 2], leave out ‘five’ and insert ‘ten’.

32, page 66 [Schedule 2], leave out lines 1 to 5.

33, page 66, line 6 [Schedule 2], leave out ‘mentioned in subsection (1)(c)(ii)’ and insert ‘relating to revocation required by subsection (1)(c)’.

34, page 66, line 20 [Schedule 2], leave out ‘(subject to subsection (2))’.

35, page 66, line 25 [Schedule 2], leave out ‘(subject to subsection (2))’.

36, page 66, line 37 [Schedule 2], leave out ‘which is three months after’ and insert ‘falling immediately after the period of three months starting with’.

37, page 67, line 44 [Schedule 2], leave out from ‘shares’ to end of line 48 and insert ‘, or the payment is made from another source and, correspondingly, the shares are no longer held by any person in relation to the award.’.

38, page 68, line 5 [Schedule 2], leave out from ‘correspondingly,’ to end of line 8 and insert ‘the shares are no longer held by any person in relation to the award.’.

39, page 68, line 23 [Schedule 2], leave out from ‘B,’ to end of line 26 and insert ‘an award may be made to A of—

(i) relevant shares, or

(ii) a sum of money the amount of which is to be determined by reference to the market value of any relevant shares at the time the sum is to be paid,’.

40, page 68, line 28 [Schedule 2], at end insert—

‘(ba) the relevant shares would be—

(i) shares (including stock) in, or

(ii) instruments within paragraph (b) of the definition of “relevant shares” in section 554I(4) issued by,

a trading company or a company which controls a trading company,’.

41, page 68, line 30 [Schedule 2], leave out from beginning to ‘and’ in line 32 and insert ‘the main purpose of which is to ensure—

(i) that the relevant shares are received, or

(ii) that the sum of money is paid,

only if a specified exit event, or an exit event within a specified description, occurs,’.

42, page 68 [Schedule 2], leave out lines 36 to 50.

43, page 69, line 7 [Schedule 2], after first ‘of’ insert ‘relevant shares or’.

44, page 69, line 10 [Schedule 2], leave out ‘(subject to subsection (3))’.

45, page 69, line 12 [Schedule 2], after first ‘of’ insert ‘relevant shares or’.

46, page 69, line 16 [Schedule 2], leave out ‘(subject to subsection (3))’.

47, page 69 [Schedule 2], leave out lines 17 and 18.

48, page 69, line 30 [Schedule 2], leave out ‘which is three months after’ and insert ‘falling immediately after the period of three months starting with’.

49, page 70, line 20 [Schedule 2], leave out ‘subsection (11) does not apply’ and insert ‘neither subsection (10A) nor subsection (11) applies’.

50, page 70, line 26 [Schedule 2], at end insert—

“(10A) This subsection applies to any earmarked shares if—

(a) A receives the shares before the end of the exit period, and

(b) the receipt of the shares by A gives rise to employment income of A which is chargeable to income tax or which is exempt income.’.

51, page 70, line 28 [Schedule 2], leave out ‘(1)(a)’ and insert ‘(1)(a)(ii)’.

52, page 70, line 34 [Schedule 2], leave out from ‘shares’ to end of line 38 and insert ‘, or the payment is made from another source and, correspondingly, the shares are no longer held by any person in relation to the award.’.

53, page 70, line 39 [Schedule 2], after ‘(10)’ insert ‘, (10A)(a)’.

54, page 70, line 40 [Schedule 2], leave out ‘three’ and insert ‘six’.

55, page 71, line 7 [Schedule 2], leave out ‘B may grant A a right (“a relevant share option”)’ and insert ‘a right (“a relevant share option”) may be granted to A’.

56, page 71, line 16 [Schedule 2], leave out from ‘terms”)’ to ‘the’ in line 21 and insert ‘the main purpose of which is to ensure that the relevant share option is not exercisable by A before a specified date (“the vesting date”) which is after the date (“the grant date”) on which the grant is made, while providing that’.

57, page 71, line 24 [Schedule 2], leave out ‘five’ and insert ‘ten’.

58, page 71 [Schedule 2], leave out lines 30 to 34.

59, page 71, line 35 [Schedule 2], leave out ‘mentioned in subsection (1)(c)(ii)’ and insert ‘relating to revocation required by subsection (1)(c)’.

60, page 71, line 44 [Schedule 2], after ‘providing’ insert ‘relevant’.

61, page 71, line 49 [Schedule 2], leave out ‘(subject to subsection (2))’.

62, page 72, line 5 [Schedule 2], leave out ‘(subject to subsection (2))’.

63, page 72, line 18 [Schedule 2], leave out ‘which is three months after’ and insert ‘falling immediately after the period of three months starting with’.

64, page 72, line 20 [Schedule 2], after ‘at’ insert ‘the end of’.

65, page 73, line 4 [Schedule 2], after ‘before’ insert ‘the end of’.

66, page 73, line 21 [Schedule 2], leave out from ‘A’ to end of line 22 and insert ‘—

(i) which is chargeable to income tax or would be chargeable apart from section 474, or

(ii) which is exempt income.’.

67, page 73, line 30 [Schedule 2], leave out from ‘A’ to ‘and’ in line 31 and insert ‘—

(i) which is chargeable to income tax or would be chargeable apart from section 474, or

(ii) which is exempt income,’.

68, page 73, line 33 [Schedule 2], leave out from ‘shares’ to end of line 37 and insert ‘, or the payment is made from another source and, correspondingly, the shares are no longer held by any person in relation to the relevant share option.’.

69, page 73, line 42 [Schedule 2], leave out from ‘correspondingly,’ to end of line 45 and insert ‘the shares are no longer held by any person in relation to the relevant share option.’.

70, page 74, line 3 [Schedule 2], leave out from ‘correspondingly,’ to end of line 6 and insert ‘the shares are no longer held by any person in relation to the relevant share option.’.

104, page 74, line 8 [Schedule 2], leave out ‘five’ and insert ‘ten’.

71, page 74, line 19 [Schedule 2], at end insert—

554LA Exclusions: earmarking for employee share schemes (4)

(1) This section applies if—

(a) there is an arrangement (“B’s employee share scheme”) under which, in respect of A’s employment with B, a right (“a relevant share option”) may be granted to A—

(i) to acquire relevant shares, or

(ii) to receive a sum of money the amount of which is to be determined by reference to the market value of any relevant shares at the time the sum is to be paid,

(b) the main purpose of the grant of the relevant share option would not be the provision of relevant benefits,

(c) the relevant shares would be—

(i) shares (including stock) in, or

(ii) instruments within paragraph (b) of the definition of “relevant shares” in section 554I(4) issued by,

a trading company or a company which controls a trading company,

(d) the grant would be made on terms (“the deferred grant terms”) the main purpose of which is to ensure that the relevant share option is exercisable by A only if a specified exit event, or an exit event within a specified description, occurs, and

(e) as at the time the grant is made, there would be a reasonable chance that the specified exit event, or an exit event within the specified description, will occur.

(2) Chapter 2 does not apply by reason of a relevant step within section 554B (by reason of which it would otherwise apply) taken by a person (“P”) if—

(a) the subject of the relevant step is relevant shares (“earmarked shares”) which are earmarked, or otherwise start being held, solely with a view to providing relevant shares, or paying a sum of money, pursuant to—

(i) a relevant share option granted to A under B’s employee share scheme as mentioned in subsection (1)(a) in relation to which the requirements of subsection (1)(b) to (e) are met, or

(ii) a relevant share option which is expected to be granted to A under B’s employee share scheme as mentioned in subsection (1)(a) and in relation to which the requirements of subsection (1)(b) to (e) would be met,

(b) the number of relevant shares of any type which are earmarked shares does not exceed the maximum number of relevant shares of that type which might reasonably be expected to be needed for providing shares, or paying a sum of money, pursuant to the relevant share option which is granted or expected to be granted, and

(c) there is no connection (direct or indirect) between the relevant step and a tax avoidance arrangement.

(3) If the relevant step mentioned in subsection (2) is taken in relation to an expected grant of a relevant share option as mentioned in subsection (2)(a)(ii), subsection (4) applies if—

(a) the grant is not made before the end of the date (“the final grant date”) falling immediately after the period of three months starting with the date on which P takes the relevant step, and

(b) as at the end of the final grant date, any of the earmarked shares continue to be held by or on behalf of P solely on the basis mentioned in subsection (2)(a).

(4) This Part has effect as if a relevant step within section 554B were taken at the end of the final grant date—

(a) the subject of which is—

(i) the shares which continue to be held as mentioned in subsection (3)(b), and

(ii) any relevant income in relation to those shares (see subsection (14)), and

(b) by reason of which Chapter 2 is to apply (subject only to section 554A(4)).

(5) Subsection (6) applies if, at any time (“the relevant time”)—

(a) any of the earmarked shares cease to be held by or on behalf of P solely on the basis mentioned in subsection (2)(a), but

(b) the shares continue to be held by or on behalf of P on the basis mentioned in section 554B(1)(a) or (b).

(6) This Part has effect as if a relevant step within section 554B were taken at the relevant time—

(a) the subject of which is—

(i) the shares mentioned in subsection (5), and

(ii) any relevant income in relation to those shares (see subsection (14)), and

(b) by reason of which Chapter 2 is to apply (subject only to section 554A(4)).

(7) Subsection (8) applies if—

(a) the relevant step mentioned in subsection (2) is taken in relation to a grant of a relevant share option made as mentioned in subsection (2)(a)(i), or

(b) the relevant step mentioned in subsection (2) is taken in relation to an expected grant of a relevant share option as mentioned in subsection (2)(a)(ii) and the grant is made before the end of the final grant date,

and the specified exit event, or an exit event within the specified description, occurs.

(8) This Part has effect as if a relevant step within section 554B were taken at the end of the exit period—

(a) the subject of which is—

(i) any of the earmarked shares to which none of subsections (9) to (11) applies, and

(ii) any relevant income in relation to any of the earmarked shares mentioned in sub-paragraph (i) (see subsection (14)), and

(b) by reason of which Chapter 2 is to apply (subject only to section 554A(4)).

(9) This subsection applies to any earmarked shares if—

(a) A exercises the relevant share option (wholly or partly) before the end of the exit period and, as a result, receives the shares, and

(b) the receipt of the shares gives rise to employment income of A—

(i) which is chargeable to income tax or would be chargeable apart from section 474, or

(ii) which is exempt income.

(10) This subsection applies to any earmarked shares if—

(a) A exercises the relevant share option (wholly or partly) before the end of the exit period and, as a result, a sum of money is paid to A as mentioned in subsection (1)(a)(ii),

(b) the payment of the sum gives rise to employment income of A—

(i) which is chargeable to income tax or would be chargeable apart from section 474, or

(ii) which is exempt income, and

(c) the payment represents the proceeds of the disposal of the shares, or the payment is made from another source and, correspondingly, the shares are no longer held by any person in relation to the relevant share option.

(11) This subsection applies to any earmarked shares if—

(a) the relevant share option becomes exercisable by A before the end of the exit period but the option lapses (in whole or in part) at or before the end of that period, and

(b) correspondingly, the shares are no longer held by any person in relation to the relevant share option.

(12) In subsections (8), (9)(a), (10)(a) and (11)(a) “the exit period” means—

(a) the period of six months starting with the date on which the exit event occurs, or

(b) if it ends earlier, the period during which the relevant share option is exercisable by A in accordance with the deferred grant terms.

(13) If the exit event is an event within section 554I(6)(a), in subsection (12)(a) the reference to six months is to be read as a reference to five years.

(14) In subsections (4)(a)(ii), (6)(a)(ii) and (8)(a)(ii) “relevant income”, in relation to any earmarked shares, means any income—

(a) which, before the relevant step is treated as being taken by subsection (4), (6) or (8) (as the case may be)—

(i) arises (directly or indirectly) from the shares, and

(ii) is the subject of a relevant step within section 554B taken by P by reason of which Chapter 2 would apply apart from section 554P, and

(b) which, at the time the relevant step is treated as being taken, continues to be held by or on behalf of P on the basis mentioned in section 554B(1)(a) or (b).’.

72, page 74, line 43 [Schedule 2], after ‘421E(1),’ insert ‘429, 443,’.

73, page 74, line 44 [Schedule 2], at end insert—

“(6A) Subsection (6E) applies if there is an acquisition of an asset within section 554C(4)(a) or (b) (“the relevant asset”) and—

(a) relevant consideration is given by A for the relevant asset of an amount equal to or greater than the market value of the relevant asset at the time of the acquisition, or

(b) ignoring any relevant consideration given for the relevant asset, the acquisition gives rise (or would give rise) to earnings of A within Chapter 1 of Part 3 from A’s employment with B—

(i) the amount of which is equal to or greater than the market value of the relevant asset at the time of the acquisition, and

(ii) which are not exempt income.

(6B) In subsection (6A) “relevant consideration”—

(a) means consideration—

(i) which is given before, or at or about, the time of the acquisition, and

(ii) which is money or money’s worth, but

(b) does not include—

(i) a promise to do anything, or

(ii) the performance of any duties of, or in connection with, an employment.

(6C) If section 437(1) or 452(1) applies in relation to the acquisition, or would apply if Chapter 3 or 4A of Part 7 (as the case may be) applied in relation to the acquisition, in subsection (6A) references to the market value of the relevant asset are to be read as references to that value determined on the basis mentioned in section 437(1) or 452(1) (as the case may be).

(6D) Subsection (6E) also applies if—

(a) there is an acquisition of an asset within section 554C(4)(a) or (b) (“the relevant asset”),

(b) the acquisition is pursuant to an employment-related securities option (within the meaning of Chapter 5 of Part 7, but ignoring section 474(1)) acquired by reason of A’s employment, or former or prospective employment, with B, and

(c) the acquisition is a chargeable event for the purposes of section 476 or would be a chargeable event apart from section 474(1).

(6E) Chapter 2 does not apply by reason of a relevant step taken after the acquisition if—

(a) the subject of the relevant step is the relevant asset, and

(b) there is no connection (direct or indirect) between the relevant step and a tax avoidance arrangement.

(6F) In subsections (6A) to (6E) “acquisition” is to be read in accordance with section 421B(2)(a).’.

74, page 75, line 4 [Schedule 2], leave out ‘a share option’ and insert ‘an employment-related securities option (within the meaning of Chapter 5 of Part 7)’.

75, page 75, line 7 [Schedule 2], after ‘tax’ insert ‘or would be chargeable apart from section 474’.

76, page 75 [Schedule 2], leave out lines 11 and 12.

77, page 75, line 28 [Schedule 2], leave out from beginning to ‘is’ in line 30 and insert ‘of 40 days starting with the day on which the relevant step mentioned in subsection (7)’.

78, page 77, line 17 [Schedule 2], leave out ‘554L’ and insert ‘554LA’.

79, page 77, line 39 [Schedule 2], leave out from beginning to end of line 40 and insert—

‘(d) subsection (1A) does not apply.

(1A) This subsection applies if it is reasonable to suppose that, in essence—

(a) at the time of the acquisition of sum or asset T, the value of sum or asset T is greater or less than the value of sum or asset S, and

(b) the difference (or any part of the difference) in the values might not have been expected applying the assumption that all relevant connected persons are acting at arm’s length of each other.

(1B) In subsection (1A)—

(a) the reference to sum or asset S is to sum or asset S so far as sum or asset T is acquired out of it, and

(b) “relevant connected person” means a person with a connection (direct or indirect) to the arrangement under which sum or asset T is acquired.’.

80, page 77, line 43 [Schedule 2], at end insert—

“(2A) Subsection (3) applies if, on its acquisition, sum or asset T is the subject of a relevant step within section 554B taken by P.’.

81, page 77, line 44 [Schedule 2], leave out ‘mentioned in subsection (1)(d)’.

82, page 78, line 4 [Schedule 2], at end insert ‘and’.

83, page 78, line 7 [Schedule 2], leave out from ‘(b)’ to end of line 18.

84, page 78, line 20 [Schedule 2], leave out from beginning to ‘and’ in line 23 and insert—

‘(a) on its acquisition, sum or asset T—

(i) is the subject of a relevant step within section 554B taken by P by reason of which Chapter 2 applies or would apply apart from subsection (3) above or any of sections 554H to 554LA, 554P or 554S, or

(ii) if sub-paragraph (i) does not apply, is held by or on behalf of P on the same basis as that on which sum or asset S was held by or on behalf of P immediately before the acquisition,’.

85, page 84, line 42 [Schedule 2], at end insert—

“(5A) And for that purpose, section 170(2) to (11) is to be read as if for “75 per cent” (wherever occurring) there were substituted “51 per cent” (with section 1154(2) of CTA 2010 applying accordingly).’

86, page 88, line 8 [Schedule 2], after ‘section’ insert ‘or section 554Z6’.

87, page 88, line 9 [Schedule 2], leave out ‘sections 554Z5 to’ and insert ‘section 554Z5 or’.

88, page 88, line 43 [Schedule 2], after ‘(10)’ insert ‘or 554LA(4), (6) or (8)’.

89, page 89, line 2 [Schedule 2], leave out ‘B may grant A a right (“a relevant share option”)’ and insert ‘a right (“a relevant share option”) may be granted to A’.

90, page 89, line 36 [Schedule 2], after ‘554L(10)’ insert ‘or 554LA(8)’.

91, page 90, line 9 [Schedule 2], leave out ‘which is three months after’ and insert ‘falling immediately after the period of three months starting with’.

92, page 90, line 11 [Schedule 2], after ‘at’ insert ‘the end of’.

93, page 96, line 20 [Schedule 2], at end insert—

“(10) In relation to times after the relief is given, the Tax Acts have effect as if this Chapter had never applied by reason of the original relevant step.’.

105, page 96, line 29 [Schedule 2], at end insert—

Chapter 3