½Û×ÓÊÓƵ

Where a person incurs a 'relevant defeat' in relation to any 'arrangements', HMRC must, within 90 days of the day on which the defeat is incurred, give the person, and those associated with them a warning notice setting out¹:

1. Ìý

   •ÌýÌýÌýÌý when the warning period begins and ends

2. Ìý

   •ÌýÌýÌýÌý the relevant defeat to which the notice relates, and

3. Ìý

   •ÌýÌýÌýÌý the implications of the issue of the notice

In the case of a corporate group, the notice must also be given to each group member. A warning notice issued to a company before it becomes a member of a corporate group is treated as issued to each group member. However, a notice will not be issued to an associated person who is a member of the same group of companies².

Where a tax avoidance scheme is used in connection with a partnership return and is defeated, the defeat is treated as a defeat for each person who was a partner in the partnership during the period covered by the