- Acceptable overseas GAAP
means the generally accepted accounting practice and principles of any of the following— • Canada;
- acceptance period
has the same meaning as in paragraph 38;
- accounting period
has the meaning given by section 61;
- accounting reference date
means the date to which the group's accounts are made up.
- appeal period
means the period during which—
- Apprentice
has the meaning specified in regulations made by the Treasury. 5 Regulations under this section— a may make provision framed by reference to a scheme (however described or named), or document, as it has effect from time to time, b may make different provision for different purposes, c may make different provision for different areas, and d may make retrospective provision.”
- armed forces accommodation allowance
means an allowance which is exempt from income tax by reason of section 297D of ITEPA 2003.”
- arrangements
includes any agreement, understanding, scheme transaction or series of transactions (whether or not legally enforceable),
- associated online advertising service
means an online service that—
- authorised HMRC officer
means an officer of Revenue and Customs who is, or is a member of a class of officers who are, authorised by the Commissioners for Her Majesty's Revenue and Customs for the purpose of this Schedule;
- business
includes trade or profession;
- charity
means a charity as defined by paragraph 1 of Schedule 6 to the Finance Act 2010;
- company
has the meaning given by paragraph 1(3);
- consolidation exemption
means any exemption in the applicable accounting standards from a requirement to consolidate revenues.
- contract settlement
means an agreement in connection with a person's liability to make a payment to HMRC under or by virtue of an enactment;
- coronavirus
has the same meaning as in the Coronavirus Act 2020 (see section 1(1) of that Act);
- coronavirus business support grant scheme
means any scheme (whether announced or operating before or after the passing of this Act), other than a scheme within subsection (2)(a) to (d), under which a public authority makes grants to businesses with the object of providing support to those businesses in connection with any effect or anticipated effect (direct or indirect) of coronavirus or coronavirus disease;
- coronavirus support payment
means a payment made (whether before or after the passing of this Act) under any of the following schemes—
- corresponding partnership case
means a corresponding case in which the limited liability partnership in question carries on a business with a view to profit in the relevant period;
- deductible clogged losses
means losses which would, apart from Part 7ZA of CTA 2010, be deductible under subsection (3) from chargeable gains accruing to the company in an accounting period. 12 A claim under subsection (9) must be made by being included in the company's tax return for the accounting period for which the claim is made.”
- designated officer
means an officer of Revenue and Customs who has been designated by the Commissioners for the purposes of this Part;
- digital services activity
has the meaning given by section 43;
- digital services revenues
has the meaning given by section 40;
- director
has the meaning given by section 250 of the Companies Act 2006;
- emissions allowance
means an allowance under paragraph 5 of Schedule 2 to the Climate Change Act 2008 relating to a trading scheme;
- employment-related scheme
means the coronavirus job retention scheme or the coronavirus statutory sick pay rebate scheme;
- error
includes— (a) any computational error, and (b) the allowance of a claim that ought not to have been allowed;
- Excluded expenses
means any expenses—
- final GAAR counteraction notice
means a notice given under— (a) paragraph 12 of Schedule 43, (b) paragraph 8 or 9 of Schedule 43A, or (c) paragraph 8 of Schedule 43B, • “GAAR procedural requirements” means the procedural requirements of Schedule 43, 43A or 43B, • “lesser adjustments” means adjustments specified in the final GAAR counteraction notice which assume a smaller tax advantage than was assumed in the protective GAAR notice or (as the case may be) the Schedule 43 or 43A notice, and • “ordinary assessing time limit”, in relation to any adjustments, means the time limit imposed by or under any enactment other than this Part for the making of the adjustments. 2 Expressions which are u
- financial instrument
means— (a) a financial instrument within the meaning of the applicable accounting standards (see section 64), or (b) a contract of insurance as defined by section 64 of FA 2012;
- flawed
means flawed when considered in the light of the principles applicable in proceedings for judicial review.
- for enforcement purposes
means for the purposes of provisions providing for—
- foreign DST charge
means a charge (known by any name) under the law of the foreign user's territory which is similar to digital services tax;
- foreign user
means a user who it is reasonable to assume— (a) in the case of an individual, is normally in a territory outside the United Kingdom;
- fungible assets
means assets of a nature to be dealt in without identifying the particular assets involved. 900K 1 For the purposes of section 900J— a pre-FA 2002 assets, b restricted assets, and c standard intangible fixed assets, are to be regarded as assets of different kinds. 2 If section 900J applies (whether or not it is a case where subsection (1) of this section has effect)— a a single asset comprising pre-FA 2002 assets is treated as itself being a pre-FA 2002 asset, b a single asset comprising restricted assets is treated as itself being a restricted asset, and c a single asset comprising standard intangible fixed assets is treated as itself being a standard intangible fixed asse
- group
has the meaning given by section 57;
- HMRC
means Her Majesty's Revenue and Customs;
- Horizon Shortfall Scheme
means the scheme established on 1 May 2020 by Post Office Limited to compensate persons who were adversely affected by accounting shortfalls related to the Horizon system;
- IAS
means— issued or adopted, from time to time, by the International Accounting Standards Board.
- insolvency procedure
has the meaning given by paragraph 8;
- item
includes any substance.”
- joint liability notice
has the meaning given by paragraph 1(2);
- land
includes any floating structure.”
- lesser adjustments
means adjustments specified in the final GAAR counteraction notice which assume a smaller tax advantage than was assumed in the protective GAAR notice or (as the case may be) the Schedule 43 or 43A notice, and • “ordinary assessing time limit”, in relation to any adjustments, means the time limit imposed by or under any enactment other than this Part for the making of the adjustments. 2 Expressions which are used in section 202 of FA 2014 (“tax enquiry”, and its being “in progress”, and “return”) have the same meaning in sections 209AA and 209AB as they have in that section (and references to completing a tax enquiry are to be read accordingly).”
- limited liability partnership
means a body incorporated under the Limited Liability Partnerships Act 2000;
- Marked oil
means any hydrocarbon oil in which a marker is present which is for the time being designated by regulations made by the Commissioners under subsection (5) below, other than marked oil which is in the fuel supply of an engine provided for propelling a vessel having been taken in to that supply in accordance with the law of the place where it was taken in. 5 The Commissioners may for the purposes of this section designate any marker which appears to them to be used for the purposes of the law of any place (whether within or outside the United Kingdom) for identifying hydrocarbon oil that is not to be used as fuel for propelling private pleasure craft. 6 In this Act “private pleas
- market value
has the same meaning as in TCGA 1992 and is to be determined in accordance with sections 272 and 273 of that Act (valuation). 7 Section 1122 of CTA 2010 (connected persons) has effect for the purposes of this section. 8 This section is to be construed as one with Part 4 of FA 1986. 9 This section has effect— a in relation to the charge to tax under section 87 of FA 1986 where— i the agreement to transfer securities is conditional and the condition is satisfied on or after the relevant date, or ii in any other case, the agreement is made on or after that date;
- marketplace transaction
means a transaction on the online marketplace between users;
- matter in question
means the matter to which an appeal relates;
- medical items
means items intended for use for medical purposes, including in particular— (a) blood;
- member
has the meaning given by section 57;
- non-banking company
means a company that is not a banking company at the time that the allowable loss, or such part of it as the election transfers, is treated as accruing by virtue of the election (see, in particular, section 171B(3) of TCGA 1992).”
- non-banking transferred-in loss relief
means the sum of any amounts that are deducted under section 2A of TCGA 1992 in determining the taxable total profits of the company of the chargeable accounting period in respect of an allowable loss, or any part of an allowable loss, that accrued to the company as a result of a non-banking loss transfer. 2 A “non-banking loss transfer” is a transfer to the company of the whole or any part of an allowable loss, by an election under section 171A of TCGA 1992 (reallocation within group), from a non-banking company. 3 In this section “non-banking company” means a company that is not a banking company at the time that the allowable loss, or such part of
- notice
means notice in writing;
- notify
means notify in writing;
- online advertising revenues
means revenues arising in connection with the provision or facilitation of online advertising;
- Online marketplace
means an online service that meets the following conditions—
- online marketplace revenues
means revenues arising in connection with an online marketplace.
- original shares
has the meaning given by section 126 of TCGA 1992;
- parent
has the meaning given by section 57;
- participator
has the meaning given by section 454 of CTA 2010;
- partner
includes purported partner, and b “partnership” includes the purported partnership. 5 In this section— • “business” includes trade or profession;
- partnership
includes the purported partnership. 5 In this section— • “business” includes trade or profession;
- Post Office Limited
means the private company limited by shares with the company number 02154540 whose registered office is 100 Wood Street, London EC2V 7ER;
- Post Office Process Review
means the review established by Post Office Limited to provide redress to postmasters who were financially impacted by previous processes or policies in relation to balance discrepancies unrelated to the Horizon system;
- post-commencement period
means the part of the straddling period falling on or after that date.
- post-review period
has the same meaning as in paragraph 41.
- pre-commencement period
means the part of the straddling period falling before 1 April 2020, and
- premises
includes any floating structure. 3 Nothing in sub-paragraph (1) enables regulations to be made authorising the examination of the interior of part of a vessel if that part is used as a dwelling.”
- private pleasure craft
has the same meaning as in Article 14(1)(c) of Council Directive 2003/96/EC (taxation of energy products etc). 7 The Treasury may by regulations provide for cases in which a vessel is treated as not being a private pleasure craft for the purposes of this Act (which may include cases in which the vessel is used in accordance with instructions given by an officer of HMRC for the purposes of removing restricted fuel from the vessel).”
- prohibited use
means a use that contravenes section 14E(1);
- provider
means the person providing the online marketplace;
- purported partner
means any person who was a member of the LLP in the relevant period;
- purported partnership return
means anything that— (a) purports to be a partnership return, and (b) is in a form, and is delivered in a way, that a partnership return could have been made and delivered in a corresponding partnership case.”
- qualifying payment
means a payment within any of sub-paragraphs (2) to (5).
- qualifying tax return
means a return made by T under section 8 of TMA 1970 for a qualifying tax year, and any accompanying accounts, statements or documents.”
- qualifying tax year
means the tax year 2015-16 and any earlier tax year, and • “qualifying tax return” means — (a) a return made by A or B under section 8 of TMA 1970 for a qualifying tax year, and any accompanying accounts, statements or documents, or (b) a return made by B under paragraph 3 of Schedule 18 to FA 1998 for an accounting period that commenced before 6 April 2016, and a qualifying tax return is of the same type as another if both fall within the same paragraph of this definition.”
- rebated fuel
has the meaning given by section 14E(3);
- recognised stock exchange
has the meaning given by section 1137 of CTA 2010;
- relevant
means relevant to the question whether the company had a tax liability or how much its tax liability was.
- relevant accounting period
means an accounting period of the group of which the provider is a member.
- relevant compensation payment
means a payment made to a company under—
- relevant conditions
has the meaning given by paragraph 10(2);
- relevant credits
means credits of the company in respect of the derivative contract which, on the assumption that the company had been carrying on the business at the pre-rental times— a would have been recognised in determining its profit or loss for a period consisting of or including those times, b would have been brought into account for the purposes of this Part, and c would not otherwise have been brought into account for tax purposes. 4 This section also applies in relation to a non-UK resident company which is a party to a derivative contract for the purpose of enabling it to generate other UK property income (within the meaning given by section 5(6)).”
- Relevant cross-border transaction
means a marketplace transaction where—
- relevant date
means—
- relevant day
means—
- Relevant enactment
means— a any of the following— i sections 12AC and 28B (enquiries into partnership returns), ii Part 4 of FA 2014 (follower notices and accelerated payment notices), and b any enactment relating to, or applying for the purposes of, an enactment within paragraph (a). 4 In relation to the relevant return, the relevant enactments apply with the necessary modifications, including in particular the following— a “partner” includes purported partner, and b “partnership” includes the purported partnership. 5 In this section— • “business” includes trade or profession;
- relevant entity
means—
- relevant information
means information of a kind specified under section 54(2);
- relevant liability
means any DST liability in relation to the group for the accounting period.
- relevant maximum
means the sum of— a 50% of the company's relevant BLAGAB chargeable gains for the accounting period, and b the amount of the company's BLAGAB deductions allowance for the accounting period. 4 A company's “relevant BLAGAB chargeable gains” for an accounting period are— a the shareholders' share of the BLAGAB chargeable gains for the accounting period, after any reduction under section 210A(2A)(a) of TCGA 1992, less b the amount of the company's BLAGAB deductions allowance for the accounting period.
- relevant obligations and liabilities
means any obligations or other liabilities relating to digital services tax;
- relevant operating expenses
has the meaning given by section 49.
- relevant other asset
means an asset by reference to which the conditions in paragraphs (c) and (d) of section 900C(2) or (as the case may be) the conditions in section 900D(2) were met, and • “the notional deduction amount”, in relation to a relevant other asset, means— (a) in a case where section 900E(2) would have applied had the company acquired the relevant other asset instead of the restricted asset, an amount equal to the market value of the relevant other asset at the time the restricted asset was acquired, and (b) in a case where section 900E(3) would have applied had the company acquired the relevant other asset instead of the restricted asset, an amount equal to the market value
- relevant percentage
means the percentage in the last row of the third column of the Table in Schedule 1 to IHTA 1984.
- relevant person
has the same meaning as in section 47;
- relevant provision
means—
- relevant purposes
means any purposes relating to digital services tax.
- relevant scheme
means a compromise or arrangement—
- relevant time
means any time— (a) after the time when the information is provided under section 54 or (if earlier) the last time by which the information may be provided in accordance with that section, and (b) before the giving of a direction under section 56 in relation to the group.
- relevant undertaking
means an undertaking in respect of which regulations have effect under— a section 15(a) of the Limited Liability Partnerships Act 2000, b section 1043 of the Companies Act 2006 (unregistered companies), or c section 1049 of the Companies Act 2006 (overseas companies). 3 Expressions used in this section and in the Companies Act 2006 have the same meaning in this section as in that Act. 60E 1 An undertaking that is not a company or a relevant undertaking qualifies as small for a tax year if one of the following conditions is met. 2 The first condition is that the undertaking's first financial year is not relevant to the tax year. 3 The second condition is that the undertaking's turnover for its last financial year that is relevant to the tax year is not more than the amount for the time being specified in the second column of item 1 of the Table in section 382(3) of the Companies Act 2006. 4 For the purposes of this section a financial year of an undertaking is “relevant to” a tax year if it ends at least 9 months before the beginning of the tax year. 5 In this section— • “relevant undertaking” has the meaning given by section 60D, and • “turnover”, in relation
- reorganisation
has the meaning given by that section;
- restricted asset
has the same meaning as in Chapter 16A, and • “standard intangible fixed asset” means an intangible fixed asset that is neither a pre-FA 2002 asset nor a restricted asset.”
- restricted fuel
has the meaning given by section 14E(2).”
- section 1259 purposes
means the purposes of determining under section 1259 the amount of profits or losses to be allocated to a partner in a firm. 4 Section 148 of TIOPA 2010 (when the participation condition is met) applies for the purposes of subsection (1) as it applies for the purposes of section 147(1)(b) of TIOPA 2010. 900I 1 A company that acquires an intangible fixed asset in pursuance of an unconditional obligation under a contract is to be treated for the purposes of this Chapter as having acquired the asset on the date on which the company became subject to that obligation or (if later) the date on which that obligation became unconditional. 2 An obligation is unconditional if i
- settlement agreement
means an agreement in writing between the appellant and an officer of Revenue and Customs that is—
- shadow director
has the meaning given by section 251 of the Companies Act 2006;
- Social media service
means an online service that meets the following conditions—
- specified
has the meaning given by section 48.
- specified date
means—
- standard intangible fixed asset
means an intangible fixed asset that is neither a pre-FA 2002 asset nor a restricted asset.”
- status determination statement
means a statement by the client that— a states that the client has concluded that the condition in section 61M(1)(d) is met in the case of the engagement and explains the reasons for that conclusion, or b states (albeit incorrectly) that the client has concluded that the condition in section 61M(1)(d) is not met in the case of the engagement and explains the reasons for that conclusion. 2 But a statement is not a status determination statement if the client fails to take reasonable care in coming to the conclusion mentioned in it. 3 For further provisions concerning status determination statements, see section 61T (client-led status disagreement process) and
- subsidiary
has the meaning given by section 57;
- Suspension Remuneration Review
means the review established by Post Office Limited to provide redress to postmasters contracted to deliver Post Office services through branches who were suspended before March 2019 and did not receive remuneration during their period of suspension.
- tax
means digital services tax;
- tax advantage
has the meaning given by section 1139 of CTA 2010.
- tax return
means— (a) a return made under section 8 of TMA 1970 and any accompanying accounts, statements or documents, or (b) a return made under paragraph 3 of Schedule 18 to FA 1998, and a tax return is of the same type as another if both fall within the same paragraph of this definition.
- tax-avoidance arrangements
means—
- tax-evasive conduct
has the meaning given by paragraph 7;
- the actual settlor
means the person who is the settlor of the property in relation to the settlement first mentioned in section 80(1). 7 Where the occasion first referred to in section 80(1) occurred before the day on which the Finance Act 2020 was passed, this section has effect as if, in subsection (2), “or (3A)(a)” were omitted.”
- the applicable accounting standards
has the meaning given by section 64;
- the applicable rate
has the same meaning as in section 67;
- the appropriate proportion
means such proportion of the total amount of UK digital services revenues arising to members of the group in the accounting period as is attributable to the relevant person.
- the commencement date
means the date on which this Act is passed.
- the Commissioners
means the Commissioners for Her Majesty's Revenue and Customs.”
- the coronavirus job retention scheme
means the scheme (as it has effect from time to time) that is the subject of the direction given by the Treasury on 15 April 2020 under section 76 of the Coronavirus Act 2020;
- the coronavirus period
means the period beginning with 1 March 2020 and ending with 1 November 2020. 7L The Treasury may by regulations amend the definition of “the coronavirus period” in sub-paragraph (7K) so as to replace the later of the dates specified in it with another date falling before 6 April 2021. 7M The power in sub-paragraph (7L) may be exercised on more than one occasion.”
- the coronavirus statutory sick pay rebate scheme
means the scheme (as it has effect from time to time) given effect to by the Statutory Sick Pay (Coronavirus) (Funding of Employers' Liabilities) Regulations 2020 (S.I. 2020/512);
- the deemed employer
means the person who, assuming one of conditions A to C in section 61N were met, would be treated as making a deemed direct payment to the worker under section 61N(3) on the making of a chain payment;
- the destination State
means— (a) in a case within paragraph (i) of sub-paragraph (1)(a), the member State concerned, and (b) in a case within paragraph (ii) of sub-paragraph (1)(a), the United Kingdom, and • “the origin State” means— (a) in a case within paragraph (i) of sub-paragraph (1)(a), the United Kingdom, and (b) in a case within paragraph (ii) of sub-paragraph (1)(a), the member State concerned. 2 The removal of the goods from the origin State is not to be treated by reason of paragraph 6(1) of Schedule 4 as a supply of goods by the supplier. 3 1 The rules in sub-paragraph (2) apply if— a during the period of 12 months beginning with the day the goods arrive in the destination Stat
- the enactments relating to stamp duty
means the Stamp Act 1891 and any enactment amending that Act or that is to be construed as one with that Act. 5 For the purposes of this section— a the value of unlisted securities is to be taken to be the market value of the securities at the date the instrument is executed;
- the filing date
has the same meaning as in Schedule 8 (see paragraph 1(1));
- the Future Fund
means the scheme of that name operated from 20 May 2020 by the British Business Bank plc on behalf of the Secretary of State;
- the Horizon system
means previous versions of the computer system used by Post Office Limited known as Horizon (and sometimes referred to as Legacy Horizon, Horizon Online or HNG-X);
- the instalments period
means the period— a beginning with the time the CT payment plan is entered into, and b ending with the day on which the final instalment of the deferred tax is due under paragraph 9. 12 1 This paragraph applies where— a a CT payment plan is entered into by a company, b during the instalments period a partial trigger event occurs in relation to a qualifying transaction listed in the plan, and c a trigger event has not previously occurred in relation to that qualifying transaction during the instalments period. 2 A partial trigger event occurs in relation to a qualifying transaction within sub-paragraph (2) of paragraph 3 if the transferee disposes of part (but not all) of the asset that is the subject of the transaction.
- the managers of an approved knowledge-intensive fund
means the person or persons having the management of an investment fund— a which is, in the opinion of HMRC Commissioners, a fund established for the purpose of investing wholly, or substantially wholly, in shares in companies which are knowledge-intensive companies at the time the shares are issued, and b which is, having met such other conditions as HMRC Commissioners consider appropriate for the purposes of this section, approved by them for those purposes.”
- the ordinary Part 2A amount
means— a the amount of the qualifying expenditure, by reference to which an allowance can be made under this Part, incurred in relation to the building or structure before the time of the sale in question, less b the total amount of the allowances under this Part arising before that time by reference to the building or structure. 7 In this section any reference to allowances under this Part is to allowances to which an entitlement has arisen under this Part or would have arisen under this Part if the building or structure had been in continuous qualifying use since it was first brought into non-residential use. 8 In this section “Part 6 allowance”, in relation t
- the origin State
means— (a) in a case within paragraph (i) of sub-paragraph (1)(a), the United Kingdom, and (b) in a case within paragraph (ii) of sub-paragraph (1)(a), the member State concerned. 2 The removal of the goods from the origin State is not to be treated by reason of paragraph 6(1) of Schedule 4 as a supply of goods by the supplier. 3 1 The rules in sub-paragraph (2) apply if— a during the period of 12 months beginning with the day the goods arrive in the destination State the supplier transfers the whole property in the goods to the customer, and b during the period beginning with the day the goods arrive in the destination State and ending immediately before the time of that
- the relevant Chapter of this Part
has the meaning given by section 900E(6). 900O In this Chapter— • “restricted asset” has the same meaning as in Chapter 16A, and • “standard intangible fixed asset” means an intangible fixed asset that is neither a pre-FA 2002 asset nor a restricted asset.”
- the relevant Chapters of this Part
means— (a) Chapter 3 (debits in respect of intangible fixed assets), (b) Chapter 15 (adjustments on change of accounting policy), and (c) Chapter 5 (calculation of tax written-down value) in so far as it has effect for the purposes of Chapters 3 and 15. 900F 1 This section applies in respect of a restricted asset of a company if it is a restricted asset by reason of section 900C or 900D. 2 The relevant Chapters of this Part have effect as if the company acquired the asset for the adjusted amount. 3 The adjusted amount is calculated as follows— • Step 1 Find the amount— (a) for which the company actually acquired the asset, or (b) if different, for which i
- the relevant date
means— a for income tax purposes, 5 April 2020, or b for corporation tax purposes, 31 March 2020.”
- the relevant day
means—
- the relevant individual
means— (a) where a claim under section 169M of TCGA 1992 is made jointly by the trustees of a settlement and a qualifying beneficiary, the qualifying beneficiary;
- the relevant period
means—
- the relevant shareholders
means the persons who— (a) immediately after the exchange, hold shares or securities in company B, and (b) immediately before the exchange, also held shares or securities in company A.
- the relevant time
means the time when the individual enters into the convertible loan agreement.
- the responsible member
has the meaning given by section 52;
- the scheme
means the scheme established under section 20, • “specified” means specified in the scheme, and • “the Commissioners”, “qualifying amount” and “qualifying agreement” have the meaning they have in section 20.
- the self-employment income support scheme
means the scheme (as it has effect from time to time) that is the subject of the direction given by the Treasury on 30 April 2020 under section 76 of the Coronavirus Act 2020.
- the threshold conditions
has the meaning given by section 46;
- the Windrush Compensation Scheme
means the scheme published by the Home Office on 3 April 2019 which provides compensation for certain categories of persons in recognition of difficulties arising out of an inability to demonstrate lawful immigration status (as that scheme is amended from time to time).
- thing
means any services, goods or other property;
- trading scheme
means a trading scheme dealt with under Part 1 of that Schedule (schemes limiting activities relating to emissions of greenhouse gas).
- transaction on the online marketplace
includes the placing on the marketplace of an order that results in an agreement, even if the agreement between the users is made otherwise than through the marketplace.
- tribunal
means the First-tier Tribunal, or where determined by or under Tribunal Procedure Rules, the Upper Tribunal.
- unlisted securities
means chargeable securities that are not listed securities within the meaning of section 48 (SDRT: listed securities and connected persons). 3 For the purposes of stamp duty reserve tax chargeable under section 87 of FA 1986 (the principal charge), the amount or value of the consideration is to be treated as being equal to— a the amount or value of the consideration for the transfer, or b if higher, the market value of the unlisted securities at the time the agreement is made. 4 Subsection (5) has effect for the purposes of stamp duty reserve tax chargeable under section 93 of FA 1986 (depositary receipts) or section 96 of that Act (clearance services). 5 If the amount or value of the consideration for any transfer of unlisted securities is less than the value of those securities at the time they are transferred, the transfer is to be treated as being for an amount of consideration in money equal to that value. 6 For the purposes of this section— a the value of unlisted securities is to be taken to be their market value;
- unpaid tax
means the total amount of tax payable by members of the group for the accounting period which remains unpaid on the date when the liability to the penalty under this paragraph arises.
- unsecured creditor
has the meaning given by— (a) section 248 of the 1986 Act (in relation to England and Wales and Scotland);
- user
has the meaning given by section 44.
- winding up accounting period
means— a the accounting period of the company that begins when the winding up starts (within the meaning of section 12(7) of CTA 2009), and b each subsequent accounting period.”