Paragraph 5

Part 7 of FA 2004 (disclosure of tax avoidance schemes);

Schedule 17 to F(No. 2)A 2017 (disclosure of tax avoidance schemes: VAT and other indirect taxes).

section 308(1) and (3) (duty of promoter in relation to notifiable proposals and notifiable arrangements);

section 309(1) (duty of person dealing with promoter outside the United Kingdom);

section 310 (duty of parties to notifiable arrangements not involving promoter);

section 310C (duty of promoter to provide updated information);

section 312(2) (duty of promoter to notify client of reference number);

section 313ZA (duty of promoter to provide details of clients).

section 316A (duty to provide additional information).

paragraph 11(1) (duty of promoter in relation to notifiable proposals);

paragraph 21(3) (duty of promoter to provide updated information);

paragraph 23(2) (duty of promoter to notify client of reference number);

paragraph 27(3) (duty of promoter to provide details of clients);

paragraph 33 (duty to provide additional information).

F9an authorised officer has determined that P has failed to comply with the provision concerned,

the appeal period has ended, and

the determination has not been overturned on appeal.

F10on appeal, the tribunal has determined for the purposes of F11section 315D(1) of FA 2004 F12or paragraph 48 of Schedule 17 to F(No.2)A 2017 that P is to be deemed not to have failed to comply with the provision concerned as P had a reasonable excuse for not doing the thing required to be done,

the appeal period has ended, and

the determination has not been overturned on appeal.