the supply of goods or services,

F19... or

the importation of goods F25... in the course of carrying on a business.

a registered pension scheme,

an annuity purchased with sums or assets held for the purposes of a registered pension scheme or a pre-2006 pension scheme, F7...

an employer-financed retirement benefits scheme,

a QROPS or former QROPS, or

an annuity purchased with sums or assets held for the purposes of a QROPS or former QROPS.

paragraph 3(1) (approval etc of third party notices) does not apply,

paragraph 4(1) (copying third party notices to taxpayer) does not apply, and

paragraph 30(1) (appeal) has effect as if it permitted an appeal on any grounds.

sub-paragraphs (3) and (4) of that paragraph (approval of tribunal) have effect as if they permitted, but did not require, an authorised officer of Revenue and Customs to obtain the approval of the tribunal, and

paragraph 31 (appeal) has effect as if it permitted an appeal on any grounds.

paragraph 2(2) only requires the notice to state this and name the parent undertaking F21, and

the references in paragraph 3(5) to naming the taxpayer are to making that statement and naming the parent undertaking.

in paragraphs 3 and 4 (approval etc of notices and copying third party notices to taxpayer), the references to the taxpayer have effect as if they were references to the parent undertaking, but

in paragraph 30(2) (no appeal in relation to taxpayer's statutory records), the reference to the taxpayer has effect as if it were a reference to the parent undertaking and each of its subsidiary undertakings.

paragraph 2(2) only requires the notice to state this, and

the references in paragraph 3(5) to naming the taxpayer are to making that statement.

in paragraph 3 (approval etc of notices), sub-paragraphs (1) and (3)(e) do not apply,

paragraph 4(1) (copying third party notices to taxpayer) does not apply,

F23paragraphs 21 and 21A (restrictions on giving taxpayer notice where taxpayer has made return) F31apply as if the notice was a taxpayer notice or taxpayer notices given to each subsidiary undertaking (or, if the notice names the subsidiary undertakings to which it relates, to each of those undertakings),

paragraph 30(1) (appeal) has effect as if it permitted an appeal on any grounds, and

in paragraph 30(2) (no appeal in relation to taxpayer's statutory records), the reference to the taxpayer has effect as if it were a reference to the parent undertaking or any of its subsidiary undertakings.

sub-paragraphs (3) and (4) of that paragraph (approval of tribunal) have effect as if they permitted, but did not require, the officer to obtain the approval of the tribunal, and

paragraph 31 (appeal) has effect as if it permitted an appeal on any grounds, but the parent undertaking may not appeal against a requirement in the notice to produce any document that forms part of the statutory records of the parent undertaking or any of its subsidiary undertakings.

there has been a change in the ownership of a company, and

in connection with that change a person (“the seller”) may be or become liable to be assessed and charged to corporation tax under F3section 710 or 713 of CTA 2010.

made a tax return under section 12AA of TMA 1970 (partnership returns), or

made a claim or election in accordance with section 42(6)(b) of TMA 1970 (partnership claims and elections),

delivered a land transaction return under Part 4 of FA 2003 (stamp duty land tax), or

made a claim under that Part of that Act,

delivered an annual tax on enveloped dwellings return or a return of the adjusted chargeable amount under Part 3 of FA 2013, or

made a claim under that Part of that Act,

paragraph 2(2) only requires the notice to state this and give a name in which the partnership is registered for any purpose F26, and

the references in paragraph 3(5) to naming the taxpayer are to making that statement and naming the partnership.

in paragraphs 3 and 4 (approval etc of notices and copying third party notices to taxpayer), the references to the taxpayer have effect as if they were references to at least one of the partners, and

in paragraph 30(2) (no appeal in relation to taxpayer's statutory records), the reference to the taxpayer has effect as if it were a reference to F17any of the partners in the partnership.

in paragraph 3 (approval etc of notices), sub-paragraphs (1) and (3)(e) do not apply,

paragraph 4(1) (copying third party notices to taxpayer) does not apply,

paragraph 30(1) (appeal) has effect as if it permitted an appeal on any grounds, and

in paragraph 30(2) (no appeal in relation to taxpayer's statutory records), the reference to the taxpayer has effect as if it were a reference to any of the partners in the partnership.

sub-paragraphs (3) and (4) of that paragraph (approval of tribunal) have effect as if they permitted, but did not require, the officer to obtain the approval of the tribunal, and

paragraph 31 (appeal) has effect as if it permitted an appeal on any grounds, but the partner to whom the notice is given may not appeal against a requirement in the notice to produce any document that forms part of that partner's statutory records.

the animals kept for the purposes of the trade, or

the products of those animals.

it appears to an officer of Revenue and Customs that a counteraction provision may apply to the person by reason of one or more transactions, and

the notice refers only to information or documents relating to the transaction (or, if there are two or more transactions, any of them).

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

section 684 of ITA 2007 (person liable to counteraction of income tax advantage)F27, or

section 733 of CTA 2010 (company liable to counteraction of corporation tax advantage).

is not in A’s possession or power, but

is in the power or possession of another relevant person in the MNE Group concerned (“B”),

“MNE Group” has the same meaning as in the Taxes (Base Erosion and Profit Shifting) (Country-by-Country Reporting) Regulations 2016 (S.I. 2016/237) (see regulation 2(3) of those Regulations);