I too am confused by this. As you say – the double counting scenario is prevented for capital disregarded in Part I of Schedule 5ZA by virtue of 25(1)(g) (as amended by SI2003/2275). For capital disregarded under Part II of 5ZA the double counting is prevented by Part II itself and the new para 23 of the Second Schedule (disregards for income other than earnings) as inserted by SI2003/2275. But I just can’t see where the double counting is prevented for non-disregarded capital.
