The disclosure of tax avoidance scheme (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 person.1
For an overview of the DOTAS regime, see A7.202.
This article considers the meaning of 'tax advantage', 'national insurance contributions advantage' and the taxes to which DOTAS applies.
Notifiable proposals or arrangements
Arrangements or proposals are notifiable under DOTAS (see A7.205–A7.206) if2:
- 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 below 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 insurance contributions advantage if appropriate), and
- Ìý
•ÌýÌýÌýÌý the main benefit,
To continue reading
View the latest version of this document, as well as thousands of others like it, sign in to Tolley+™ Research or register for a free trial
Web page updated on 17 Mar 2025 15:38