{
  "url": "https://openlegislation.uk/finance-act-2014/section-272A",
  "json_url": "https://openlegislation.uk/finance-act-2014/section-272A.json",
  "legislation": "ukpga/2014/26",
  "legislation_title": "Finance Act 2014",
  "legislation_url": "https://openlegislation.uk/finance-act-2014",
  "path": "section/272A",
  "kind": "section",
  "number": "272A",
  "heading": "Application of Schedule 36 FA 2008 powers",
  "text": "(1) Schedule 36 to FA 2008 (information and inspection powers) applies for a relevant purpose in relation to a relevant person as it applies for the purpose of checking the tax position of a person as if—\n(a) any provisions which can have no application for that purpose were omitted (for example, paragraphs 10A, 11, 12A and 12B);\n(b) references to “the taxpayer” were to “the relevant person”;\n(c) references to prejudice to the assessment or collection of tax included prejudice to the fulfilment of a relevant purpose;\n(d) references to “business documents” included any documents (or copies of documents) in connection with any relevant arrangements or relevant proposal;\n(e) references to a pending appeal relating to tax were to a pending appeal by the relevant person under this Part;\n(f) in paragraph 13, after “paragraph 39” there were inserted “ of this Schedule and paragraph 2(3A) of Schedule 35 to FA 2014 ”;\n(g) paragraphs 21 to 21B were omitted;\n(h) paragraph 25 were omitted;\n(i) in paragraph 29(1) for “a taxpayer”, in the first place it occurs, there were substituted “ a relevant person ”;\n(j) Part 7 (penalties) were omitted (but see Schedule 35 of this Act).\n(2) A person is “relevant” if—\n(a) the officer suspects that the person carries on, or has in the past carried on, a business as a promoter in relation to a relevant proposal or relevant arrangements and—\n(i) the officer suspects that the person has met a threshold condition,\n(ii) the officer suspects the person could be given a defeat notice, or\n(iii) the officer suspects the person promotes, or has promoted, arrangements, or proposals for such arrangements, of a description that the officer suspects could be specified in a stop notice,\n(b) the officer suspects that—\n(i) the person made a relevant transfer, or\n(ii) the person is a person to whom a relevant transfer was made, or\n(c) the person is, or was, subject to a stop notice, conduct notice or monitoring notice.\n(3) The following are “relevant purposes” in relation to a relevant person—\n(a) determining whether the relevant person carries on or has in the past carried on a business as a promoter in relation to a relevant proposal or relevant arrangements;\n(b) determining whether the relevant person has met a threshold condition;\n(c) determining whether the relevant person could be given a defeat notice;\n(d) determining whether the person has provided false or misleading information or documents in relation to a stop notice, conduct notice or monitoring notice;\n(e) determining whether arrangements, or proposals for such arrangements, that an officer suspects are promoted by the relevant person are of a description that could be specified in a stop notice;\n(f) enabling HMRC to understand the operation of arrangements, or proposals for such arrangements, that an officer suspects are promoted by the relevant person;\n(g) identifying any other person who has a connection with the relevant person that results (whether solely because of that connection or otherwise) in the relevant person being a member of a promotion structure;\n(h) determining whether the relevant person made a relevant transfer, and if so to whom;\n(i) determining whether a relevant transfer was made to the relevant person, and if so by whom;\n(j) monitoring compliance with any stop notice, conduct notice or monitoring notice the relevant person is subject to.\n(4) In this section—\n(a) reference to compliance with a stop notice, conduct notice or monitoring notice includes compliance with any provisions of this Part that a person subject to such a notice must comply with;\n(b) reference to a person “promoting” is to be construed in accordance with section 236A(7);\n(c) “relevant transfer” has the meaning it has in paragraph 5 of Schedule 33A (promotion structures).",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "S. 272A inserted (with effect in accordance with s. 121(6) of the amending Act) by Finance Act 2021 (c. 26), Sch. 30 para. 4"
    }
  ],
  "outstanding_effects": [
    {
      "type": "repealed",
      "affecting": "ukpga/2026/11",
      "affecting_title": "Finance Act 2026"
    }
  ],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2014/26/section/272A",
    "retrieved_at": "2026-10-29T09:07:29.129035+00:00",
    "licence": "OGL-UK-3.0",
    "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
    "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
  }
}