A person (P) is liable to pay a penalty if—
stating that a tax advantage arising from particular tax arrangements is to be counteracted,
The penalty is 60% of the value of the counteracted advantage.
Schedule 43C—
In this section "tax document" means any return, claim or other document submitted in compliance (or purported compliance) with any provision of, or made under, an Act.
In this section the reference to giving a tax document to HMRC is to be interpreted in accordance with paragraph 11(g) and (h) of Schedule 43C.