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HMRC has the power to prevent persons promoting certain arrangements that may give rise to a tax advantage. HMRC can also require such persons to maintain certain conduct and monitor them if they fail to do so. This is known as the promoters of tax avoidance scheme (POTAS) regime. For an overview of the regime, see A7.301.

This article discusses the key terms for the regime:

1. Ìý

   •ÌýÌýÌýÌý promoters

2. Ìý

   •ÌýÌýÌýÌý relevant proposals and arrangements

3. Ìý

   •ÌýÌýÌýÌý tax advantage

4. Ìý

   •ÌýÌýÌýÌý intermediaries

It is not possible to provide a single definition of 'client' as whether a person is a 'client' is measured over different time periods, depending on the context.

The definitions of the terms 'promoters', 'promotion structure', 'relevant proposals', 'relevant arrangements' and 'tax advantage' discussed below also apply to HMRC's power to publish details of suspected tax avoidance schemes and details of any person suspected of making the scheme available to taxpayers¹. This power is similar to the naming and shaming power that HMRC has to publish details