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17.—(1) Where HMRC suspect that a person (“P”) is the promoter or introducer of a proposal or arrangements which may be a notifiable contribution proposal or notifiable contribution arrangements, HMRC may by written notice require P to state—
(a)whether in P’s opinion the proposal or arrangements are notifiable by P, and
(b)if not, the reasons for P’s opinion.
(2) A notice must specify the proposal or arrangements to which it relates.
(3) For the purpose of paragraph (1)(b)—
(a)it is not sufficient to refer to the fact that a lawyer or other professional has given an opinion,
(b)the reasons must show, by reference to this Part and the Descriptions Regulations why P thinks the proposal or arrangements are not notifiable by P, and
(c)in particular, if P asserts that the arrangements do not fall within any description prescribed by the Descriptions Regulations the reasons must provide sufficient information to enable HMRC to confirm the assertion.
(4) P must comply with a requirement under or by virtue of paragraph (1) within—
(a)the prescribed period, or
(b)such longer period as HMRC may direct.
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