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  "The bank that disclosed these schemes to HM Revenue & Customs (HMRC) has adopted the Banking Code of Practice on Taxation which contains a commitment not to engage in tax avoidance," he said.
  
  "The government is clear that these are not transactions that a bank that has adopted the code should be undertaking.
  
  "We do not take today's action lightly, but the potential tax loss from this scheme and the history of previous abuse in this area mean that this is a circumstance where the decision to change the law with full retrospective effect is justified."
  
  Why it is, "has adopted" and not 'had' is indeed a puzzle Howard.

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