摘要:This article critically evaluates the rules applicable to the new Promoter Penalties regime. The article explains the background to the rules and describes the elements of the rules and the manner in which they will operate. Throughout, the article raises queries in relation to how the rules will work and identifies concerns with their operation. An example is the article's review of the operation of the Promoter Penalty regime alongside rules which essentially allow taxpayers to adopt positions that provide them with a "reasonably arguable" position. The article also queries the meaning of "promoter" explaining that it may not be clear-cut that a professional adviser is not a promoter