Part 13Tax avoidance
Chapter 1Transactions in securities
Procedure for counteraction of income tax advantages
F1695Notice of enquiry
(1)
An officer of Revenue and Customs may enquire into a transaction or transactions if—
(a)
the officer has reason to believe that section 684 (person liable to counteraction of income tax advantage) may apply to a person (“the taxpayer”) in respect of the transaction or transactions, and
(b)
the officer notifies the taxpayer of his intention to do so.
(2)
The notification may be given at any time not more than 6 years after the end of the tax year to which the income tax advantage in question relates.