Paragraph 19

section 23E of ITTOIA 2005 would (ignoring paragraph 20) apply in relation to a relevant benefit arising to T,

the relevant benefit is a loan or quasi-loan in relation to which paragraph 1(2) applies,

an accelerated payment notice, or a partner payment notice, relating to a relevant charge (the “accelerated payment notice”) has been given under Chapter 3 of Part 4 of FA 2014,

T makes a payment (the “accelerated payment”) in respect of the understated or disputed tax to which the notice relates,

the accelerated payment is made on or before F15 April 2019, and

the amount of the loan or quasi-loan that, at the end of F25 April 2019, is outstanding for the purposes of paragraph 1 (see paragraphs 3 to 14) is equal to or less than the amount of the accelerated payment.