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 actions that must be taken after making the disclosure as required under DOTAS. For details of who should make the disclosure and the deadline for doing so, see A7.230–A7.231.
Scheme reference numbers—overview
In summary, once the disclosure has been submitted by way of the appropriate form, HMRC processes the notification and allocates a scheme reference number (SRN). This SRN is then sent to the person who made the disclosure.
If the disclosure was made by a promoter, they must pass the SRN to their clients, who must then pass on the SRN to any others who may be party to the
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