(1) Where the Revenue Commissioners have reasonable grounds for believing that -
(a) a person is the promoter of a transaction that may be a disclosable transaction, or
(b) a person has entered into a transaction that may form part of a disclosable transaction, which if it were such a transaction would require the person to comply with section 817G,
the Commissioners may by written notice (in this Chapter referred to as a ' pre-disclosure enquiry ') require the person to state -
(i) whether, in that person's opinion, the transaction is a disclosable transaction, and
(ii) if in that person's opinion the transaction is not considered to be a disclosable transaction, the reasons for that opinion.
(2) A notice under subsection (1) shall specify the transaction to which it relates.
(3) The reasons referred to in subsection (1)(ii) (in this Chapter referred to as a 'statement of reasons') shall demonstrate, by reference to this Chapter and regulations made under it, why the person holds the
…