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 discusses the circumstances in which HMRC can apply to the tribunal under FA 2004, s 314A for an order that the proposals/arrangements are notifiable under DOTAS. For an overview of the information powers that can be used by HMRC in relation to DOTAS, see A7.240.
For the definition of arrangements and proposals, see A7.205–A7.206.
Application for orders in relation to proposals/arrangements that have not been notified under DOTAS
HMRC has two powers that can appear to be very similar:
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