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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 power granted to HMRC under FA 2004, s 310A² to require further information from the scheme user where the user makes an incomplete disclosure under DOTAS, or from the scheme user/promoter where the disclosure is complete but HMRC needs further information. For the action that HMRC can take in relation to an incomplete disclosure by the promoter, see A7.244.

For an overview of the