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 https://www.parliament.uk/business/publi...

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

foi.team@hmrc.gsi.gov.uk on behalf of FOI Central Team, HM Revenue and Customs

Our ref: FOI2018/01296

Dear Mr Sawyer,

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HMRC Freedom of Information Act Team