Paragraph 2
(1)
An agreement that the tax advantage to a person accruing from the operation of the scheme be shared to any extent with another party to it or another person promoting it.
(2)
A person is a promoter of a scheme if, in the course of a trade, profession or business which involves the provision to other persons of services relating to taxation—
(a)
he is to any extent responsible for the design of the proposed arrangements; or
(b)
he invites persons to enter into contracts for the implementation of the proposed arrangements.