Taxes Consolidation Act 1997 section 817RI

Specified arrangements

Section 817RI excludes certain "specified arrangements" from the scope of hallmark A.3 under the mandatory disclosure rules for cross-border arrangements, where the tax advantage arises solely from reliefs or exemptions listed in Schedule 34 and the arrangement is not a tax avoidance transaction.

• A "specified arrangement" is one falling within a class of arrangements listed in Schedule 34; such an arrangement is deemed not to contain hallmark A.3 if it satisfies the main benefit test, meets the conditions in subsection (3), and would otherwise trigger that hallmark.
• The conditions are that the tax advantage arises solely because the arrangement falls within Schedule 34, and the arrangement is not a tax avoidance transaction within the meaning of section 811C.
• The exclusion is designed to prevent a large volume of routine, non-avoidance transactions from becoming reportable, reducing the administrative burden on intermediaries and taxpayers.
• Examples of arrangements that may benefit from this exclusion include approved profit-sharing schemes, approved salary sacrifice arrangements, and approved retirement benefit schemes.