Link Report

(c) a transaction is one to which section 817J applies, and two or more transactions would have been assigned the same transaction number if they had been disclosed by a promoter under section 817E rather than by the person who entered into the transaction under section 817H, or

(c) a transaction is one to which section 817J applies, and two or more transactions would have been assigned the same transaction number if they had been disclosed by a promoter under section 817E rather than by the person who entered into the transaction under section 817H, or

(b) both transactions were assigned the same transaction number under section 817HB(1)(a),

(c) a transaction is one to which section 817J applies, and two or more transactions would have been assigned the same transaction number if they had been disclosed by a promoter under section 817E rather than by the person who entered into the transaction under section 817H, or

(a) a reference to a ‘scheme’ is a reference to a transaction to which section 817S(2) applies, and

(a)section 817S(3) applies in relation to the first transaction and in the opinion of a Revenue officer, the provisions of the Acts or the principles and reasoning given by the Appeal Commissioners in making a determination in relation to the first transaction would, if applied in making a determination in an appeal against an assessment, being an assessment—

(3) Where a person to whom a Revenue officer may send, or cause to be sent, a payment notice under section 817S(3) is a scheme participant, a Revenue officer may send a payment notice to any other scheme participants notwithstanding that an assessment made in respect of those scheme participants has been appealed and the appeal has not yet been determined by the Appeal Commissioners.

(a) state the amount of the tax assessed on a scheme participant resulting from the denial or withdrawal of a tax advantage, having had regard to the determination referred to in section 817S(3),

(5) A scheme participant may request a Revenue officer to review the payment notice by submitting a notice (in this section referred to as a ‘review notice’) in writing within 30 days from the payment notice giving reasons why the scheme participant does not consider a transaction entered into by that person to be the same as, or substantially similar to, the transaction in respect of which another scheme participant has received a payment notice under section 817S(3).

(11) Subsections (5), (6) and (7) of section 817S shall apply to a payment notice issued under this section as if it were a notice issued under section 817S.

(11) Subsections (5), (6) and (7) of section 817S shall apply to a payment notice issued under this section as if it were a notice issued under section 817S.