Taxes Consolidation Act 1997 section 817N

Supplemental matters

Section 817N provides supplemental rules confirming that a disclosure under the mandatory disclosure regime is made on a wholly non-judgemental basis and does not affect Revenue's powers under the general anti-avoidance provisions.

• Where a promoter discloses a transaction and provides a client list, the disclosure is made entirely without prejudice as to whether the transaction is a tax avoidance transaction within the meaning of section 811C.
• Where a scheme user discloses a transaction, the disclosure is similarly made without prejudice as to whether it constitutes a tax avoidance transaction.
• A disclosure under Chapter 3 does not constitute, and is not equivalent to, a protective notification under section 811A or section 811D.
• Nothing in the mandatory disclosure regime prevents Revenue from making any enquiry or taking any action under the general anti-avoidance or protective notification provisions.