Commentary

A7.303 Promoters of tax avoidance schemes—conduct notices

Administration and compliance

A7.303 Promoters of tax avoidance schemes—conduct notices

A7.303 Promoters of tax avoidance schemes—conduct notices

For the latest New Development, see ND.1740.

Promoters of tax avoidance schemes who satisfy one or more 'threshold conditions' relating to previous behaviour or who regularly promote avoidance schemes which are defeated are subject to a compliance regime. For an overview of the regime, see A7.301. This article considers the issue of a conduct notice where the promoter has met any of the threshold conditions in the previous three years. For details of the issue of a conduct notice for defeated schemes, see A7.304.

The promoters of tax avoidance schemes rules are also referred to as 'POTAS'.

Conduct notices

An authorised HMRC officer may issue a conduct notice where they becomes aware, at any time, that a person carrying on business as a promoter has triggered one of certain threshold conditions within the previous

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