Paragraph 12
(1)
A designated HMRC officer who has received a notice or notices under paragraph 11 must, having considered any opinion of the GAAR Advisory Panel about the tax arrangements, give the taxpayer a written notice setting out whether the tax advantage arising from the arrangements is to be counteracted under the general anti-abuse rule.
(2)
If the notice states that a tax advantage is to be counteracted, it must also set out—
(a)
the adjustments required to give effect to the counteraction, and
(b)
if relevant, any steps that the taxpayer is required to take to give effect to it.