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Duties of promoters and other persons to disclose information—overview

The duty to disclose normally falls on the promoter of the notifiable proposal or arrangements. But special rules apply when:

1. Ìý

   •ÌýÌýÌýÌý a non-UK based promoter does not disclose the arrangements – here the client of the promoter is responsible for disclosure

2. Ìý

   •ÌýÌýÌýÌý the promoter is a lawyer and legal professional privilege prevents them from giving all or part of the prescribed information to HMRC – here the lawyer's client must disclose the arrangements

3. Ìý

   •ÌýÌýÌýÌý there is no promoter (for example the arrangements are devised 'in-house' for use within that entity or a corporate group to which it belongs) – here the arrangements must be disclosed by the user of the arrangements

The requirements described above are contained in F(No 2)A 2017, Sch 17. The sections below explore the requirements in more detail.

Duty of promoter in relation to a notifiable proposal or notifiable arrangements—F(No 2)A 2017, Sch 17, para 11(1), 12(1)

For