On 12 January 2018, HMRC published guidance on the Serial Tax Avoidance Regime legislation contained in Schedule 18, Finance Act 2016.
The guidance closely follows the legislation and indicates how HMRC intend to operate the regime in practice. The following examples in the guidance are helpful:
• examples illustrating the penalty aggregation rules and the application of the cap in the follower notice regime (paragraph 5.3)
• examples illustrating the value of the counteracted advantage where additional tax is due (ignoring group relief), where the intended effect of the arrangement is to create or increase a loss, where payment of tax is deferred and where the arrangement relates to VAT (paragraphs 5.5 to 5.8)
• examples illustrating the effects of warning notices having been issued to a company before it joins a group (paragraph 7.3) and illustrating the application of the rules to corporate groups that are also VAT groups (paragraph 7.5).
A copy of the guidance can be viewed here.