Related Commentary  

212A(1)  A person (P) is liable to pay a penalty if–

(a)P has been given a notice under

(i)paragraph 12 of Schedule 43,

(ii)paragraph 8 or 9 of Schedule 43A, or

(iii)paragraph 8 of Schedule 43B,

stating that a tax advantage arising from particular tax arrangements is to be counteracted,

(b)a tax document has been given to HMRC on the basis that the tax advantage arises to P from those arrangements,

(c)that document was given to HMRC–

(i)by P, or

(ii)by another person in circumstances where P knew, or ought to have known, that the other person gave the document on the basis mentioned in paragraph (b), and

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