A7.205 DOTAS—notifiable arrangements
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 'notifiable arrangements', as the DOTAS regime requires such arrangements to be disclosed to HMRC. For the meaning of 'notifiable proposals', which must also be disclosed to HMRC under DOTAS, see A7.206.
Meaning of notifiable arrangements
The concept of 'notifiable arrangements' is at the heart of the DOTAS rules, as if the 'arrangements' are 'notifiable', they must be reported to HMRC under DOTAS2.
The term 'arrangements' is defined widely so as to include any scheme, transaction or series of transactions3.
The 'arrangements' are 'notifiable arrangements' under DOTAS if4:
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