HMRC’s GAAR process in respect of a tax avoidance scheme.
My client implemented a tax avoidance scheme a few years ago (not on my advice I hasten to add). Many individuals seem to have used the same scheme and the promoter who devised it was handling the HMRC enquiries on what I believe was a representative sample arrangement.
My client has not heard anything from HMRC or the promoter for a while but has now received something called a ‘notice of binding’ which refers to the GAAR advisory panel. I am aware that the panel can give opinions on the reasonableness of schemes and that theprocedures changed recently to allow it to consider a group of cases together but beyond that I am not sure about the significance of this ‘notice of binding’.
Does my client have to do anything or is it simply a question of sitting back and seeing what happens? My client is still...
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