Having received the opinion notice or notices from the sub-panel1, a designated HMRC officer2 must consider the opinion or opinions expressed therein3 and issue a written notice to the taxpayer setting out whether the tax advantage4 arising from the arrangements is to be counteracted under the GAAR5. If the notice states that the tax advantage is to be counteracted, it must also set out the adjustments required to give effect to the counteraction and any steps that the taxpayer is required to take to give effect to it6. There is no right of appeal against the issue of such
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