{
  "url": "https://openlegislation.uk/tax-avoidance-schemes-promoters-and-prescribed-circumstances-regulations-2004/note",
  "json_url": "https://openlegislation.uk/tax-avoidance-schemes-promoters-and-prescribed-circumstances-regulations-2004/note.json",
  "legislation": "uksi/2004/1865",
  "legislation_title": "The Tax Avoidance Schemes (Promoters and Prescribed Circumstances) Regulations 2004",
  "legislation_url": "https://openlegislation.uk/tax-avoidance-schemes-promoters-and-prescribed-circumstances-regulations-2004",
  "path": "note",
  "kind": "note",
  "number": null,
  "heading": "Explanatory note",
  "text": "(This note is not part of the Regulations)\nThese Regulations prescribe circumstances in which a person is not to be treated as a promoter in relation to tax avoidance schemes for the purposes of Part 7 of the Finance Act 2004 (“the 2004 Act”).\nRegulation 1 provides for the citation, commencement and interpretation of the Regulations.\nRegulation 2 prescribes circumstances in which a company is not to be treated as a promoter. The circumstances prescribed are those in which the promoter and the company to whom services relating to taxation are provided are members of the same group.\nRegulation 3 prescribes circumstances in which a person is not to be treated as a promoter. The circumstances prescribed are those in which the person is an employee of an employer who is either a promoter of, or a person entering into any transaction forming part of, proposed arrangements or arrangements.\nRegulation 4 prescribes various circumstances in which a person to some extent responsible for the design of proposed arrangements or arrangements is not to be treated as a promoter under section 307(1)(a)(i) or (b)(i) of the 2004 Act.\nRegulation 5 prescribes circumstances in which a person is not to be treated as a promoter under section 307(1)(b)(ii) of the 2004 Act. The circumstances prescribed are those in which the person is not connected with another person who is a promoter under section 307(1)(a)(i) or (b)(i) of that Act in relation to arrangements or substantially similar arrangements.\nThese Regulations do not impose any new costs on business.",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/uksi/2004/1865/note",
    "retrieved_at": "2026-10-29T05:22:22.125268+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."
}