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Commentary

A7.215 DOTAS hallmarks—overview

Administration and compliance

A7.215 DOTAS hallmarks—overview

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 person1.

For an overview of the DOTAS regime, see A7.202.

This article is an overview of the hallmarks and lists which hallmarks must be considered in different situations.

Hallmarks

Arrangements or proposals are notifiable under DOTAS (see A7.205–A7.206) if2:

  1. Ìý

    •ÌýÌýÌýÌý they fall within any of the prescribed 'hallmarks' (see below)

  2. 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

  3. Ìý

    •ÌýÌýÌýÌý the main benefit, or one of the main benefits, that might be expected from the arrangements is the tax advantage (or national insurance contributions advantage if appropriate)

For the definition

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