HMRC has the power to stop 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. For the key definitions, see A7.301A.
This article considers the issue of a conduct notice where the promoter has met any of the threshold conditions (see A7.302) in the previous three years.
For details of the issue of a conduct notice for defeated schemes, see A7.304.
A conduct notice can also be given to a partnership. See A7.313.
Conduct notices
An authorised HMRC officer may issue a conduct notice where they become aware, at any time, that a person 'carrying on business as a promoter' (see A7.301A) has met one or more of the threshold conditions within the previous three years (except where a conduct or monitoring notice is already in effect)1.
Note that a conduct
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