8 Confidentiality where no promoter involved

(1) This Regulation applies to a transaction which—

(a) gives rise to the tax advantage expected to be obtained, and

(b) complies with the condition specified in paragraph (2).

(2) The condition referred to in paragraph (1)(b) is that the person implementing the transaction would, but for the requirements of section 817G of the Principal Act, wish to keep the way in which the transaction gives rise to the tax advantage confidential from the Revenue Commissioners at any time after the specified date and a purpose for doing so is any of the purposes referred to in Regulation 7(2)(c).