Commentary

A7.241 Pre-disclosure enquiry

Administration and compliance

A7.241 Pre-disclosure enquiry

A7.241 Pre-disclosure enquiry

If HMRC suspect that a person is the promoter of a proposal/arrangement or the introducer of a proposal which may be notifiable, they may issue a notice to that person requiring him to state whether, in his opinion, that proposal/arrangement is notifiable and, if not, to set out his reasons for that belief1. The notice must specify the proposal or arrangement in question. It is not sufficient for the person concerned to refer to the fact that a lawyer or other professional has given an opinion that the proposal or arrangement is not notifiable: the reasons given

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