Taxes Consolidation Act 1997 Schedule 34

Specified arrangements referred to in section 817RI

Schedule 34 lists the classes of arrangements that qualify as "specified arrangements" for the purposes of section 817RI, thereby excluding them from hallmark A.3 under the mandatory disclosure rules for cross-border arrangements.

• Schedule 34 identifies thirteen classes of arrangements that are treated as specified arrangements for the purposes of section 817RI, covering approved pension schemes, employee share schemes, woodland reliefs, and approved salary sacrifice arrangements.
• Where an arrangement falls within one of these classes and meets the conditions in section 817RI, it is deemed not to contain hallmark A.3, meaning it does not become reportable solely because it uses standardised documentation available to multiple taxpayers.
• The listed arrangements are all either Revenue-approved schemes or reliefs expressly provided for in the TCA 1997, reflecting the fact that they represent routine, non-avoidance transactions.
• The schedule was introduced by the Finance Act 2020 and subsequently amended by the Finance Acts of 2021 and 2022 to add further classes of arrangement.