HMRC has published guidance on the tax avoidance enablers legislation introduced in the F(No 2)A 2017, s 65 and Sch 16.
The documents cover enablers of abusive and defeated tax arrangements; who is classed as an enabler; general anti-abuse rule advisory panel opinions on tax avoidance; and penalties.
An enabler is any person who is responsible, to any extent, for the design, marketing or otherwise helping another person to enter into abusive tax arrangements. When these are defeated in court, each person who enabled those arrangements may be liable to a penalty.
The guidance covers the interaction between the enablers legislation and the accountancy bodies’ Professional Conduct in Relation to Taxation, as well as legally privileged communications with lawyers.
Details are on GOV.UK at here.