Guidance on prohibiting promotion of certain tax avoidance schemes (CC/FS91)
This explainer summarizes HM Revenue & Customs guidance on the prohibition of promoting certain tax avoidance schemes (POP). It covers what the rule bans, who is affected, penalties, and what to do if you disagree with a penalty decision. Information is drawn from HMRC’s CC/FS91 factsheet published 7 October 2026.
What the guidance covers
The guidance describes a prohibition on promoting certain tax avoidance schemes. Promoting includes activities intended to encourage others to participate in a scheme that avoids tax. The rules define “promote” and “arrangements” to include advice, marketing, or other assistance that helps set up or run a scheme. The factsheet notes penalties can be civil or criminal and explains rights if penalties are being considered.
Key facts you should know
- The prohibition targets promoters of certain tax avoidance schemes.
- “Promote” covers guidance, marketing, or support that helps set up or run an avoidance scheme.
- The guidance outlines penalties if you promote such schemes and your rights if a penalty is issued.
- The document is guidance for 2026 and reflects HMRC’s positions at the time of writing.
Who is affected
The rules apply to individuals and organizations that promote certain tax avoidance schemes. This can include advisers, firms, and others who help implement or market avoidance arrangements. The factsheet emphasizes understanding what counts as promotion and what counts as an arrangement under the policy.
Practical next steps if you’re involved
If you may be affected, review whether your activities could be considered promotion or support for avoidance schemes. Seek clarity from HMRC guidance or your legal adviser. If a penalty decision is being considered, you have rights outlined in the document, including how to respond and seek support. The guide also points to help resources and how to obtain assistance.
Limits, questions, and further help
Guidance is for reference and reflects HMRC’s position at publication. It may be updated, and the factsheet notes it is “for guidance only.” If any part is unclear, check the latest HMRC pages or contact relevant help channels listed in the guidance. This explainer does not render legal advice.
Which sources did Setup in Bahrain review?
Setup in Bahrain reviewed the following source material before preparing this explanatory article.
The links remain visible so readers can inspect the evidence, compare dates and context, and confirm current requirements with the relevant authority.
- gov.uk — evidence source reviewed for this article.
Information and responsibility notice: This article is general information based on the cited material available when published. It is not legal, tax, immigration, medical, financial, banking, or investment advice; it does not create a professional-client relationship; and it is not a guarantee of outcome, availability, accuracy, or eligibility. Rules, schedules, prices, and third-party information can change. Confirm material decisions with the relevant authority and an appropriately qualified adviser before acting.