Upon receipt of the opinion notice (or notices) the designated officer must then advise the taxpayer in writing whether or not the arrangements are to be counteracted. Thus, HMRC are not bound to follow the decision of the Advisory Panel. Any final notice of counteraction must set out the adjustments to be made and (if relevant) any steps that the taxpayer is required to take to give effect to the counteraction.

(FA 2013, Sch. 43, para. 12)

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