Tax Collection and Management (Wales) Act 2016 section 81G

Final counteraction notice

Section 81G sets out the requirements for the final counteraction notice that the Welsh Revenue Authority must issue after considering a taxpayer's representations in response to a preliminary counteraction notice.

• After the 45-day representation period (or any agreed extension) has expired, WRA must issue a final counteraction notice to the taxpayer stating whether the tax advantage will be counteracted.
• WRA must take into account any written representations the taxpayer has made before deciding whether to proceed with counteraction.
• Where counteraction is to proceed, the notice must specify the adjustment required, how it will be given effect (whether through amendment of a return under enquiry or through a WRA assessment), and any amount the taxpayer must pay.
• Where WRA decides not to counteract the tax advantage, the final notice must explain the reasons for that decision.