Finance (No. 2) Act 2017

36 (1) HMRC may publish information about— U.K.

(a) any notifiable arrangements, or proposed notifiable arrangements, to which a reference number is allocated under paragraph 22;

(b) any person who is a promoter in relation to the notifiable arrangements or, in the case of proposed notifiable arrangements, the notifiable proposal.

(2) The information that may be published is (subject to sub-paragraph (4))—

(a) any information relating to arrangements within sub-paragraph (1)(a), or a person within sub-paragraph (1)(b), that is prescribed information for the purposes of paragraph 11, 12, 17 or 18;

(b) any ruling of a court or tribunal relating to any such arrangements or person (in that person⿿s capacity as a promoter in relation to a notifiable proposal or arrangements);

(c) the number of persons in any period who enter into transactions forming part of notifiable arrangements within sub-paragraph (1)(a);

(d) any other information that HMRC considers it appropriate to publish for the purpose of identifying arrangements within sub-paragraph (1)(a) or a person within sub-paragraph (1)(b).

(3) The information may be published in any manner that HMRC considers appropriate.

(4) No information may be published under this paragraph that identifies a person who enters into a transaction forming part of notifiable arrangements within sub-paragraph (1)(a).

(5) But where a person who is a promoter within sub-paragraph (1)(b) is also a person mentioned in sub-paragraph (4), nothing in sub-paragraph (4) is to be taken as preventing the publication under this paragraph of information so far as relating to the person⿿s activities as a promoter.

(6) Before publishing any information under this paragraph that identifies a person as a promoter within sub-paragraph (1)(b), HMRC must—

(a) inform the person that they are considering doing so, and

(b) give the person reasonable opportunity to make representations about whether it should be published.

Commencement Information

I1 Sch. 17 para. 36 in force at Royal Assent for specified purposes and at 1.1.2018 otherwise, see s. 66(4)