603. Counteraction And Penalty To Be Applied If Tax Arrangements Are Abusive. | Taxation Law | LexisNexis

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603. Counteraction and penalty to be applied if tax arrangements are abusive.

If tax arrangements are abusive¹, any tax advantages arising from those arrangements are to be countered by appropriate adjustments on a just and reasonable basis². The adjustment may be made to the tax in respect of which the tax advantage was obtained, or it may be made to any other tax within the scope of the GAAR

(18) Tax Avoidance

591. Regime for disclosure of tax avoidance schemes.

592. Promoters and introducers.

593. Notifiable arrangements or proposals.

594. The duty to notify.

595. The scheme reference number.

596. Penalties for failure to disclose notifiable arrangements or notifiable proposals.

597. The introduction of the general anti-abuse rule ('GAAR').

598. Scope of the general anti-abuse rule.

599. Tax arrangements.

600. The double reasonableness test for abusiveness.

601. Role of HM Revenue and Customs guidance.

602. Case law concerning GAAR.

603. Counteraction and penalty to be applied if tax arrangements are abusive.

604. Initial action.

605. Representations from the taxpayer.

606. Referrals to the GAAR Advisory Panel.

607. Opinion of the GAAR Advisory Panel.

608. Final decision.

609. Follower notices.

610. Accelerated payment.

611. Promoters of tax avoidance schemes.

612. Serial tax avoidance.

613. Large businesses: tax strategies and sanctions.