SCHEDULES
SCHEDULE 18Serial tax avoidance
PART 2Entry into the regime and basic concepts
2Duty to give warning notice
1
This paragraph applies where a person incurs a relevant defeat in relation to any arrangements.
2
HMRC must give the person a written notice (a “warning notice”).
3
The notice must be given within the period of 90 days beginning with the day on which the relevant defeat is incurred.
4
The notice must—
a
set out when the warning period begins and ends (see paragraph 3),
b
specify the relevant defeat to which the notice relates, and
5
A warning notice given by virtue of paragraph 49 must also explain the effect of paragraph 51 (information in certain cases involving partnerships).
6
In this Schedule “arrangements” includes any agreement, understanding, scheme, transaction or series of transactions (whether or not legally enforceable).
7
For the meaning of “relevant defeat” and provision about when a relevant defeat is incurred see paragraph 11.