604. Initial action.

If HM Revenue and Customs form a view that particular tax arrangements giving rise to a tax advantage may be abusive, a designated HMRC officer1 has to follow particular procedural arrangements2 before effecting any counteraction3. For example, the first step that the designated HMRC officer must take is to issue a written notice to the person who has received the tax advantage ('the taxpayer') setting out the arrangements and the

tax advantage and why the officer considers that the taxpayer has received a tax advantage as a result of tax arrangements that are abusive. The notice must also set out the counteraction that the officer considers ought to be taken as well as advising the taxpayer of the next steps in the procedural process, specifically the taxpayer's right to make representations, and what will happen if representations are, or are not, made