[209AA Protective GAAR notices]

[209AA  Protective GAAR notices]

[(1)     An officer of Revenue and Customs may give a written notice (a “protective GAAR notice”) to a person stating that the officer considers—

(a)     that a tax advantage might have arisen to the person from tax arrangements that are abusive, and

(b)     that, on the assumption that the advantage does arise from tax arrangements that are abusive, it ought to be counteracted under section 209.

(2)     The protective GAAR notice must be given within the ordinary assessing time limit applicable to the proposed adjustments.

(3)     But if—

(a)     a tax enquiry is in progress into a return made by the person, and

(b)

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