607. Opinion of the GAAR Advisory Panel.

On receipt of a referral from a designated HMRC officer1, the Chair of the GAAR Advisory Panel2 must arrange for a sub-panel consisting of three members to consider it3. The sub-panel may invite the taxpayer or the designated HMRC officer or both to supply further information, specifying in that invitation the date by which the information should be provided4.

The sub-panel must then consider the question as to whether or not the entering into and carrying out of the tax arrangements5 is a reasonable course of action in relation to the relevant tax provisions, having regard to all the circumstances6.