On 20 October 2017, UK HMRC published draft guidance on new legislation for enablers of defeated tax avoidance schemes. The legislation essentially provides that a person is liable for a penalty when the abusive arrangements they have enabled are defeated (tax advantage counteracted by HMRC). For this purpose, a person who has enabled abusive tax arrangements is defined as a person who:
- Is a designer of arrangements;
- Is a manager of arrangements;
- Marketed the arrangements;
- Is an enabling pa…