# The Indirect Taxes (Notifiable Arrangements) Regulations 2017, Regulation 12: Premium fees

Extent: E+W+S+N.I.

(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.

---
Source: https://www.legislation.gov.uk/uksi/2017/1216/regulation/12 (the official version)
Page: https://openlegislation.uk/indirect-taxes-notifiable-arrangements-regulations-2017/regulation-12
Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives.

