Regulation 4 Descriptions 1 and 2: confidentiality

After regulation 6(2) insert—

“(2A)

Cases where arrangements will be prescribed under paragraph (2) include, but are not limited to, where—

(a)

a promoter does not provide to the user of the arrangements (“the user”), or prevents or discourages the user from retaining, any promotional materials, data or written professional advice relating to those arrangements; and

(b)

it might reasonably be expected that the reason for doing so is to keep the arrangements confidential from HMRC in order to facilitate repeated or continued use of any element of those arrangements.”.