{
  "url": "https://openlegislation.uk/finance-act-2021/schedule-28/paragraph-12",
  "json_url": "https://openlegislation.uk/finance-act-2021/schedule-28/paragraph-12.json",
  "legislation": "ukpga/2021/26",
  "legislation_title": "Finance Act 2021",
  "legislation_url": "https://openlegislation.uk/finance-act-2021",
  "path": "schedule/28/paragraph/12",
  "kind": "paragraph",
  "number": "12",
  "heading": null,
  "text": "(1) In Schedule 31, paragraph 5 is amended as follows.\n(2) In sub-paragraph (2)—\n(a) in paragraph (a), for “20%” substitute “ 12% ”;\n(b) after paragraph (a), insert—\n“(aa) the total amount of the penalties under section 208A(3) for which the relevant partners are liable is 8% of the value of the denied advantage,”;\n(c) in paragraph (b), after “the penalty” insert “ under section 208(2) or 208A(3) (as modified by this paragraph) ”.\n(3) In sub-paragraph (5), after “penalties” insert “ under section 208(2) (as modified by this paragraph) ”.\n(4) In sub-paragraph (6), after “paragraph 4(2)” insert “ or 4A ”.\n(5) In sub-paragraph (7)(a), after “penalties” insert “ under section 208(2) ”.\n(6) After sub-paragraph (9), insert—\n“(9A) The right of appeal under section 214A extends to—\n(a) a decision that penalties under section 208A(3) are payable by the relevant partners by virtue of this paragraph, and\n(b) a decision as to the total amount of those penalties payable by those partners,\nbut not to a decision as to the appropriate share of, or the amount of a penalty payable by, a relevant partner.\n(9B) Section 214A(3) applies to an appeal by virtue of sub-paragraph (9A)(a) as it applies to an appeal under section 214A(1).\n(9C) Section 214A(5) applies to an appeal by virtue of sub-paragraph (9A)(a), and section 214A(6) to an appeal by virtue of sub-paragraph (9A)(b).”\n(7) In sub-paragraph (11), after “(2)(a)” insert “ and (aa) ”.",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2021/26/schedule/28/paragraph/12",
    "retrieved_at": "2026-10-29T08:58:11.025653+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}