IHTM09151 - Avoidance: introduction

You need be on the alert for

• tax avoidance schemes
• variations on their themes
• unusual transactions
• any attempted exploitation of the rules

Although some transactions may be fully documented and appear authentic you need to look at the overall effect of the series or combination of transactions in order to identify the real purpose of the scheme.  If you do not understand what is going on then you should ask the taxpayers to explain the transactions.  If you are still not clear about the arrangement then you should consult Technical at an early stage.

In some cases it may be necessary to see correspondence relating to the setting up of the transaction, notes of meetings, faxes, e-mails, earlier drafts, memoranda of understanding and supplementary agreements between those involved.