Tax Avoidance:Written question - 152724 - "very complex nature of the arrangements"

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Dear HM Revenue and Customs,

With reference to "Tax Avoidance:Written question - 152724" found here

Stride's answer says "Enquiries into DR tax avoidance cases can be time consuming and take several years because of the very complex nature of the arrangements"

1) Can you give me any documents which detail the penalty policy for taxpayers subjected the 2019 Loan Charge?

2) Can you confirm that the "very complex nature of the arrangements" will be taken into account when deciding on penalties for arrangement caught under the 2019 Loan Charge?

3) Can you provide me with the guidance document to be used by taxpayers to determine if a very complex arrangement would be subject to the 2019 Loan Charge?

Yours faithfully,

Chris Sawyer on behalf of FOI Central Team, HM Revenue and Customs

Our ref: FOI2018/01296

Dear Mr Sawyer,

Freedom of Information Act 2000 Acknowledgement

Thank you for your communication of 21st June which has been passed to
HMRC's Freedom of Information Team.

We have allocated the above reference which you should quote if you need
to contact us.

The Team will arrange for a reply to be sent to you which will either
comply with HMRC's obligations under Freedom of Information Act or, if we
think it's an enquiry that we don't need to address under the terms of the
Act, let you know why. If it is the latter we will, if possible, pass it
on to a more appropriate part of the Department for answer.

Yours sincerely

HMRC Freedom of Information Act Team