½Û×ÓÊÓƵ

HMRC is entitled to issue a stop notice where an officer suspects that the person is promoting arrangements or proposals for arrangements that meet either²:

1. Ìý

   •ÌýÌýÌýÌý condition A and either condition B or C

2. Ìý

   •ÌýÌýÌýÌý conditions B and D

From a VAT and indirect tax perspective only condition A and condition C are relevant as B and D relate to direct tax. The relevant sections of condition A and C that relate to VAT and indirect taxes are discussed below.

1. Ìý

   •ÌýÌýÌýÌý Condition A³ is that arrangements of that description would be the same, or similar, in form or effect to arrangements or proposed arrangements to those that have been notified under the disclosure of tax avoidance schemes: VAT and other indirect taxes rules (DASVOIT)⁴ and a scheme reference number has been issued (see V5.213B below)

2. Ìý

   HMRC has the power to enact legislation that include new schemes that meet condition A⁵

3. Ìý

   •ÌýÌýÌýÌý Condition C⁶