Taxation (International and Other Provisions) Act 2010 section 89

Contents of counteraction notice

Section 89 sets out what a counteraction notice issued by HMRC may contain when they are taking action to counteract a scheme that has been designed to exploit double taxation arrangements.

• A counteraction notice specifies the adjustments HMRC consider necessary to counteract the tax advantage arising from the scheme.
• The notice may include adjustments to the amount of any relief, tax credit, or repayment of tax that the person is entitled to.
• The notice may also include adjustments to the amount of income, profits, or gains on which the person is chargeable to tax.
• The contents of the notice reflect a minor change in the law compared to the previous legislation, broadening the scope of what adjustments can be specified.