Introduction Details of the Schedule
7.Part 1 inserts new sections 196B to 196I after section 196A FA 2004. These provisions have effect on the contribution paid between 29 November 2011 and 21 February 2012 under an ABC arrangement.
8.However, new section 196G also applies to pre-November arrangements that are SFAs. In addition, it contains provisions that have effect on certain events that take place on or after 21 March 2012. There are two types of events. The first type places a person in a more advantageous tax position as a result of the application of the new section 196G. The second type relates to an employer ceasing to be chargeable to tax as set out in new section 196H.
9.Part 2 (paragraphs 4-14) introduces transitional provisions for ABC arrangements where the contribution was paid before 29 November 2011 and the SFA rules do not apply. For those arrangements where the contribution was paid before 22 February 2012, which are ‘acceptable’ SFAs(3), the transitional provision is new section 196G in Part 1 (detail in the next section). If they are unacceptable SFAs(4), then Part 4 (see paragraph 13 below) applies from 22 February and new section 196G in Part 1 only applies to events that occur between 29 November and 21 February.
10.There are also provisions to recover excess relief when an employer ceases to be chargeable to tax by regarding the date of such cessation as the date on which the arrangement is completed. These provisions have effect from 21 March 2012.
11.Part 3 inserts new sections 196B to 196L after section 196A FA 2004. These provisions have effect on the contribution paid on or after 22 February 2012 under an ABC arrangement.
12.However, new section 196I in Part 3 contains provisions that have effect on certain events that take place on or after 21 March 2012. There are two types of events. The first type places a person in a more advantageous tax position as a result of the application of the new section 196I. The second type relates to an employer ceasing to be chargeable to tax as set out in new section 196J in Part 3.
13.Part 4 (paragraphs 18-31) introduces transitional provisions for those ABC arrangements where the contribution was paid before 22 February 2012, the arrangement is not an acceptable SFA and Part 2 does not apply. There are also provisions similar to those included in new section 196J in Part 3 and these have effect from 21 March 2012.
14.Part 5 (paragraphs 32-42) provides for minor and related changes to the SFA rules. They have effect in relation to arrangements whenever made but only on those amounts arising on or after 21 March 2012.