Paragraph 1
Where—
(a)
a person (“T”) has entered into abusive tax arrangements, and
(b)
T incurs a defeat in respect of the arrangements,
a penalty is payable by each person who enabled the arrangements.
Where—
a person (“T”) has entered into abusive tax arrangements, and
T incurs a defeat in respect of the arrangements,
a penalty is payable by each person who enabled the arrangements.