These rules for avoidance arrangements apply to all taxes where the inaccuracy is contained in a return or document submitted on or after 16 November 2017, which relates to a tax period that began on or after 6 April 2017 and ended after 15 November 2017.

For other tax periods, the normal rules apply when considering whether the person has failed to take reasonable care, see CH81120.

A person (P) seeking to demonstrate they took reasonable care cannot rely on disqualified advice, see below, in respect of an avoidance arrangement.

Disqualified advice

Advice is disqualified if any of the following apply

the advice was given by an `interested person'

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