Commentary

A7.220 Standardised tax products

Administration and compliance

A7.220 Standardised tax products

A7.220 Standardised tax products

This hallmark covers arrangements which involve the use of standardised tax products. Subject to exemptions, arrangements fall within the provisions if1:

  1.  

    •     they have standardised documentation to enable the client to implement the scheme

  2.  

    •     the form of the documentation is determined by the promoter, and not tailored, to any material extent, to reflect the circumstances of the client

  3.  

    •     a client must enter into a specific transaction or series of transactions that are standardised, or substantially standardised in form, and

  4.  

    •     either the main purpose of the arrangements is to enable a person to obtain a tax advantage, or the arrangements would be unlikely to be entered into but for the expectation of obtaining a tax advantage

With effect from 23 February 2016, the test as to whether arrangements are a tax product is whether an

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