Paragraph 3
(1)
An agreement that payment to a promoter of the scheme be contingent in whole or in part on the tax advantage accruing from the operation of the scheme.
(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.