Regulation 8 Descriptions 1 and 2: confidentiality

Insert as regulation 7(2)—

“(2)

Arrangements are also prescribed if—

(a)

paragraphs (1)(a) to (c) are met; and

(b)

if there had been a promoter in relation to the arrangements, it might reasonably have been expected that they would, but for the requirements of these Regulations, wish to have kept the way in which any element of the arrangements (including the way in which the arrangements were structured) that secured the tax advantage confidential from HMRC at any time following the material date, and a reason for doing so would be to facilitate repeated or continued use of the same element, or substantially the same element, in the future.”.