CG44140 - Targeted rules to prevent income to capital converter schemes by companies - notice provisions
TCGA92/S184G and H notices may be issued before or after a self assessment return is made and (exceptionally) may be made on a discovery basis after the return enquiry window has closed.
The only effect of the notice is to switch on the legislation in relation to the arrangement(s).
Notices under TCGA92/S184G and H may only be made by Assistant Directors in Capital Gains Technical Group. If you have established the relevant facts and considered them in the light of the guidance in CG44100+ you should re-submit your case to the capital gains specialists at Anti-Avoidance Group (Investigations) who will confirm whether Capital Gains Technical Group would issue a notice. You should do this before you mention the issue of a notice in correspondence with the company or its advisers.