Commentary

A7.230 What each person has to disclose

Administration and compliance

A7.230 What each person has to disclose

Making disclosures

A7.230 What each person has to disclose

The information required to be disclosed by promoters, persons dealing with promoters outside the UK and parties to notifiable arrangements not involving a promoter must be provided 'in a form and manner specified by the Board'1 and is specified by regulations2, ie currently via one or more of the forms AAG.

The basic requirement in all cases is stated to be3:

'“… sufficient information as might reasonably be expected to enable an officer of HMRC to comprehend the manner in which the proposal or arrangements are intended to operate …”'

However forms AAG require a considerable amount of detail, and therefore information relating to the arrangement in question, including each element (namely each step) of the arrangements together with the relevant statutory provisions. Most schemes involve multiple and connected steps, and any explanation must be carefully detailed and referenced to relevant statutory provisions,

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