612. Serial Tax Avoidance. | Taxation Law | LexisNexis

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612. Serial tax avoidance.

A special statutory regime applies to serial tax avoiders¹. These rules are aimed² at persons who have entered into tax avoidance schemes that have been defeated by the GAAR³, subject to a follower notice⁴ or are notifiable under the DOTAS regime⁵. Such persons may be given a warning notice by HMRC requiring the person to send extra information to HMRC

(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.