817HADuty of person who obtains tax advantage

(1) Any person who obtains or seeks to obtain a tax advantage from a disclosable transaction shall be a chargeable person for the purposes of Part 41A.

(2) A person who enters into any transaction which is or forms part of a disclosable transaction shall, in a timely manner, provide any other person who obtains or seeks to obtain a tax advantage from that disclosable transaction with the transaction number for that disclosable transaction so as to allow that person comply with their obligations under this section.

(3) A person who obtains or seeks to obtain a tax advantage from a disclosable transaction shall include the transaction number relating to the disclosable transaction in the return, within the meaning of Part 41A, for any chargeable period, within the meaning of Part 41A, in which the person—

(a) entered into any transaction which is or forms part of a disclosable transaction, or

(b) obtains, or seeks to obtain, a tax advantage from the disclosable transaction.

(4) Where a person who obtains or seeks to obtain a tax advantage from a disclosable transaction which was not assigned a transaction number, or where that person was not provided with a transaction number, then that person shall be deemed to have complied with the obligation under subsection (3) if that person—

(a) did not have an obligation to disclose that transaction under section 817F, 817G or 817H,

(b) provides a Revenue officer^[2]>, by the specified return date for the chargeable period, within the meaning assigned to it by section 959A,^<[2] with the specified information in relation to that transaction, and

(c) without unreasonable delay, provides a Revenue officer with any other information that the officer may reasonably require for the purposes of deciding if an application should be made to the relevant court under section 817O(3)(a).