817NSupplemental matters.

(1) Where a promoter provides the Revenue Commissioners with specified information relating to a disclosable transaction and the client list in respect of that disclosable transaction, the provision of that information shall, as respects any person included on the client list who implements the transaction, be wholly without prejudice as to ^[2]>whether any opinion that the disclosable transaction concerned was a tax avoidance transaction, if such an opinion were to be formed by the Revenue Commissioners, would be correct.^<[2][2]>whether or not the disclosable transaction concerned was a tax avoidance transaction within the meaning of section 811C.^<[2]

(2) Where a person, other than a promoter, provides the Revenue Commissioners with specified information relating to a disclosable transaction the person shall be treated as making that information available wholly without prejudice as to ^[3]>whether any opinion that the disclosable transaction concerned was a tax avoidance transaction, if such an opinion were to be formed by the Revenue Commissioners, would be correct.^<[3][3]>whether or not the disclosable transaction concerned was a tax avoidance transaction within the meaning of section 811C.^<[3]

(3) Where a person provides the Revenue Commissioners with specified information relating to a disclosable transaction, the provision of that information shall not be regarded as being, or being equivalent to, the delivery of a protective notification by that person in relation to the transaction for the purposes of section ^[4]>811A^<[4][4]>811A or 811D^<[4].

(4) Nothing in this Chapter shall be construed as preventing the Revenue Commissioners from—

(a) making any enquiry, or

(b) taking any action, at any time in connection with ^[5]>section 811 or 811A^<[5][5]>section 811, 811A, 811C or 811D^<[5].