A7.331 Serial tax avoidance—warning noticesWhere a person incurs a 'relevant defeat' in relation to any 'arrangements', HMRC must, within 90 days of the day on which the defeat is incurred, give the person, and those associated with them a warning notice setting out1: • when the warning period begins and ends • the relevant defeat to which the notice relates, and • the implications of the issue of the noticeIn the case of a corporate group, the notice must also be given to each group member. A warning notice issued to a company before it becomes a member of a corporate group is treated as issued to each group member. However, a notice will not be issued to an associated person who is a member of the same group of companies2.Where a tax
Where a person incurs a 'relevant defeat' in relation to any 'arrangements', HMRC must, within 90 days of the day on which the defeat is incurred, give the person, and those associated with them a warning notice setting out1:
• when the warning period begins and ends
• the relevant defeat to which the notice relates, and
• the implications of the issue of the notice
In the case of a corporate group, the notice must also be given to each group member. A warning notice issued to a company before it becomes a member of a corporate group is treated as issued to each group member. However, a notice will not be issued to an associated person who is a member of the same group of companies2.
Where a tax
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