The disclosure of tax avoidance schemes (DOTAS) rules require certain persons, usually promoters of schemes, but also users in certain circumstances, to provide HMRC with information about schemes falling within certain descriptions, known as 'hallmarks'. The person must tell HMRC how the scheme is intended to work, usually within five days of the date the scheme is made available to any person1.
HMRC's internal processes for handing tax avoidance schemes are detailed in AHP4000. DOTAS is one way in which HMRC finds out about new avoidance schemes, see AHP3000.
Notifiable proposals and arrangements
The term 'arrangements' is defined widely so as to include any scheme, transaction or series of transactions2.
Arrangements are notifiable under DOTAS if3:
- Ìý
•ÌýÌýÌýÌý they fall within any of the prescribed 'hallmarks' (see A7.215 for income tax, corporation tax, capital gains tax, national insurance contributions and apprenticeship levy, and see A7.203 for inheritance tax and annual tax on enveloped dwellings)
- Ìý
•ÌýÌýÌýÌý they enable, or might be expected to enable, any person to obtain a tax advantage (or national
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Web page updated on 17 Mar 2025 16:19