A7.243 Doubt as to notifiability

Administration and compliance

A7.243 Doubt as to notifiability

A7.243 Doubt as to notifiability

Where HMRC suspect that a proposal/arrangements may be notifiable, they may apply to the Tribunal for it to order that those particular proposal/arrangements be treated as notifiable1. The Tribunal will make the order only if it is satisfied that HMRC2:


    •     have taken all reasonable steps to establish whether they are notifiable. 'Reasonable steps' may (but need not) include requiring the promoter to state whether, in his opinion, the arrangements are notifiable and if not to give reasons for that opinion3, and


    •     have reasonable grounds for suspecting that the proposal/arrangements may be notifiable. Grounds

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