Regulation 12 Premium feesI1

United Kingdom

(1)

An arrangement which meets the following description is a notifiable arrangement.

(2)

It might reasonably be expected, were it not for this regulation, that a promoter (“P”) of the arrangement or another person (“Q”) would be able to obtain a premium fee in relation to—

(a)

the arrangement; or

(b)

any element of the arrangement which obtains, or which may obtain, a tax advantage.

(3)

In paragraph (2), “premium fee” means a fee which is—

(a)

obtained from a person experienced in receiving services of the type provided by P or Q;

(b)

to a significant extent attributable to the tax advantage obtained, or which may be obtained, by the arrangement or any element of the arrangement; and

(c)

to any extent contingent upon that tax advantage being obtained as a matter of law.

Annotations

Commencement

I1: Reg. 12 in force at 1.1.2018, see reg. 1