A7.242 Order to disclose

A7.242 Order to disclose

HMRC may apply to the Tribunal for an order that a proposal/or arrangements are notifiable1. The application must specify the proposal or arrangements concerned and the promoter. The Tribunal may only make an order if it is satisfied that the proposal/arrangements are notifiable under the relevant statutory criteria2, and that the person specified is in fact a promoter (see A7.202).

For cases in which the First-tier Tribunal, after considering all the relevant criteria at length, granted HMRC an order that arrangements were notifiable, see Hyrax Resourcing and others3, EDF Tax Limited4 and Opus Bestpay Ltd5.

Such an

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