Paragraph 10 F1

In this Schedule—

• “deferrable exit charge” has the meaning given by paragraph 4(1)(a);

• “deferred exit charge” has the meaning given by paragraph 4(2);

• “double taxation arrangements” means arrangements made by two or more territories with a view to affording relief from double taxation;

• “economically significant activity” has the meaning given by section 13A(4) of the 1992 Act (reading references to a company as references to trustees);

• “exit charge” means—

  1. (a)

     for the purposes of paragraph 2, any amount of capital gains tax which a person is liable to pay for a tax year which the person would not be liable to pay if gains arising by virtue of section 25 of the 1992 Act in the tax year were ignored;

  2. (b)

     for the purposes of paragraph 3, any amount of capital gains tax which the relevant trustees are liable to pay for a tax year which they would not be liable to pay if gains arising by virtue of section 80 of the 1992 Act in the tax year were ignored;

• “right to freedom of establishment” means a right protected by—

  1. (a)

     Article 49 of the Treaty on the Functioning of the European Union, or

  2. (b)

     Article 31 of the EEA agreement;

• “taxpayer” has the meaning given by paragraph 4(2);

• “trade” includes a profession or vocation.