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- Heading
- Introduction
- Burden of proof in these proceedings
- Procedural point
- Evidence before the FTT
- Additional background facts
- The arrangements under consideration
- Step one
- Step two
- Step three
- Step four
- Issue 1 - was Moir a “promoter” of “notifiable arrangements” as defined by sections 306 and 307 FA 2004 ?
- Issue 2 - if so, did Moir fail to comply with its obligations under sections 308 and 313A FA 2004 ?
- Issue 3 – if so, does Moir have a reasonable excuse for its non-compliance?
- Issue 4 - if not, what quantum of penalty is Moir liable to pay?
- Conclusions