{
  "url": "https://openlegislation.uk/indirect-taxes-notifiable-arrangements-regulations-2017/regulation-12",
  "json_url": "https://openlegislation.uk/indirect-taxes-notifiable-arrangements-regulations-2017/regulation-12.json",
  "legislation": "uksi/2017/1216",
  "legislation_title": "The Indirect Taxes (Notifiable Arrangements) Regulations 2017",
  "legislation_url": "https://openlegislation.uk/indirect-taxes-notifiable-arrangements-regulations-2017",
  "path": "regulation/12",
  "kind": "regulation",
  "number": "12",
  "heading": "Premium fees",
  "text": "(1) An arrangement which meets the following description is a notifiable arrangement.\n(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—\n(a) the arrangement; or\n(b) any element of the arrangement which obtains, or which may obtain, a tax advantage.\n(3) In paragraph (2), “premium fee” means a fee which is—\n(a) obtained from a person experienced in receiving services of the type provided by P or Q;\n(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\n(c) to any extent contingent upon that tax advantage being obtained as a matter of law.",
  "extent": "E+W+S+N.I.",
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "I",
      "label": "I1",
      "text": "Reg. 12 in force at 1.1.2018, see reg. 1"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/uksi/2017/1216/regulation/12",
    "retrieved_at": "2026-10-28T23:05:11.938269+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "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."
}