SCHEDULE 30 Section 208 [or 208A] Penalty: Value of the Denied Advantage

SCHEDULE 30 Section 208 [or 208A] Penalty: Value of the Denied Advantage

Section 209

Introduction

1

This Schedule applies for the purposes of calculating penalties under section 209.

Value of denied advantage: normal rule

2

(1)     The value of the denied advantage is the additional amount due or payable in respect of tax as a result of counteracting the denied advantage.

(2)     The reference in sub-paragraph (1) to the additional amount due or payable includes a reference to—

(a)     an amount payable to HMRC having erroneously been paid by way of repayment of tax, and

(b)     an amount which would be repayable by HMRC if the denied advantage were not counteracted.

(3)     The following are ignored in calculating the value of the denied advantage—

(a)     group relief, and

(b)

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