Commentary

A7.233 Reference numbers procedures

Administration and compliance

A7.233 Reference numbers procedures

A7.233 Reference numbers procedures

The scheme reference number (SRN) system is a means of identifying users of disclosed schemes. In summary, HMRC allocate a SRN to schemes when they are disclosed, and provide it to the person who makes the disclosure. This is normally a promoter of the scheme, but where the person required to disclose the scheme is a scheme user, HMRC will provide the number directly to him. Promoters are then required to pass the SRN to clients who use the scheme, who must then report it back to HMRC, normally on a tax return affected by using the scheme. This confirms that the scheme has been used by the client. Complications will arise when a recalcitrant promoter fails to properly inform the client and explain the importance of the SRN. Amendments have been made to the scheme to clarify the position in relation to multiple promoters (see below) after research revealed gaps and defects in the SRN system which prevented the identification of users.

The procedures for reference numbers are contained in both legislation1 and regulations2.

HMRC maintain on their website a list of scheme reference numbers (SRN) for which the duty on promoters and/or clients to notify the SRN to clients and parties respectively no longer applies, and they update this periodically. However, the numbers are likely to be meaningless to the average taxpayer who might become involved in a scheme, without proper explanation from the promoter or tax adviser.

Allocation of reference number

Where a person makes a

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