Case studies

"LexisLibrary gives us the most relevant and recent cases and always has the latest information on them. It makes research so much easier. We're more cost-effective for our clients and more efficient each day"

Advocates

Access all 35 documents on Disclosure of tax avoidance schemes (DOTAS)

GET ACCESS NOW

GLOSSARY

Disclosure of tax avoidance schemes (DOTAS) definition

Published by a LexisNexis Private Client expert

What does Disclosure of tax avoidance schemes (DOTAS) mean?

disclosure of tax avoidance schemes rules oblige scheme promoters, taxpayers or their advisers to inform HMRC about certain arrangements for avoiding tax.

Speed up all aspects of your legal work with tools that help you to work faster and smarter. Win cases, close deals and grow your business–all whilst saving time and reducing risk.

Sources of DOTAS rules—table

Sources of DOTAS rules—table The following table summarises the main sources of the rules and guidance on the disclosure of tax avoidance schemes (DOTAS) and the disclosure of avoidance schemes relating to VAT and other indirect taxes (DASVOIT). It is intended as a quick reference guide and is therefore not exhaustive. It does not include amending or repealed legislation. It includes the rules on income tax, corporation tax, capital gains tax (CGT), national insurance contributions (NICs), inheritance tax (IHT), stamp duty land tax (SDLT), the annual tax on enveloped dwellings (ATED) and the apprenticeship levy. For guidance on the DOTAS and DASVOIT rules see the following Practice Notes: • Disclosure of tax avoidance schemes—income tax, corporation tax, CGT and NICs • Disclosure of tax avoidance schemes—SDLT • Disclosure of tax avoidance schemes—VAT and other indirect taxes (DASVOIT) • Disclosure of tax avoidance schemes—IHT • Disclosure of tax avoidance schemes—procedure, and • Promoters of tax avoidance schemes Source Tax Brief description FA 2004, ss 306–319 (Part 7) Income...

Quick guide to follower notices and accelerated payment notices—checklist

Quick guide to follower notices and accelerated payment notices—checklist The following table in this Checklist summarises the key points to note about follower notices and accelerated payment notices (APNs)/partner payment notices (PPNs). For more information, see Practice Notes: • Follower notices, and • Accelerated payment notices Key points Follower notices APNs/PPNs Purpose Anti-avoidance:• provided four conditions (A–D) are met, HMRC can give follower notices to taxpayers who have used an avoidance scheme that has been shown to fail in a relevant judicial ruling (ie in another person's litigation)• penalties for failing to comply with a follower notice incentivise the recipient of notice to concede to HMRC's view and to take any necessary corrective action, such as amending a return or a claim, or to drop its appeal in accordance with the earlier ruling and therefore save HMRC the time and expense of having to litigate the same issue again Anti-avoidance:• provided three conditions (A–C) are met, HMRC can give an APN/PPN to a taxpayer to require payment of the tax...

Discover our 2 Checklists on Disclosure of tax avoidance schemes (DOTAS)

IHT—anti-avoidance provisions

IHT—anti-avoidance provisions FORTHCOMING CHANGE relating to changes to APR and BPR: At Autumn Budget 2024 on 30 October 2024, the government announced an intention to significantly reduce the amount of APR and BPR on qualifying property from April 2026. Subject to consultation (expected in early 2025), the 100% rate of relief will be restricted so that it will no longer apply to the whole value of the qualifying agricultural or business property, but will instead only apply to the first £1m of combined value. See News Analysis: Autumn Budget 2024—Private Client analysis—Inheritance tax. This Practice Note provides an overview of the main anti-avoidance measures that HMRC seek to rely on to prevent the avoidance of inheritance tax (IHT) in the UK. Note that the main body of the IHT rules is covered in several other Practice Notes. These are referenced where relevant. While not necessarily drafted as anti-avoidance provisions, there are various conditions and provisions which restrict the availability of IHT reliefs and exemptions (eg the requirements for...

Historical IHT planning schemes

Historical IHT planning schemes Introduction The core legislation found in the Inheritance Tax Act 1984 (IHTA 1984) and the former capital transfer tax regime contained an oversight. There was nothing to prevent an individual seeking to reduce exposure to inheritance tax (IHT) on death from making a lifetime gift (with the hope of surviving at least seven years) while continuing to have the use or enjoyment of the gifted asset. Under the legislation, it was therefore possible for an individual effectively to give away their home for IHT purposes while continuing to occupy it. The gift with reservation of benefit (GWR or GROB) provisions introduced by section 102 and Schedule 20 to the Finance Act 1986 (FA 1986) were designed to close this loophole. Where the GROB provisions apply, the gifted (or in some cases, substituted) property is generally treated as remaining part of the donor’s estate for IHT purposes while the donor continues to benefit. The provisions can apply if (among other things) an individual...

Discover our 22 Practice Notes on Disclosure of tax avoidance schemes (DOTAS)

Private Client weekly highlights—5 June 2025

This week’s edition of Private Client highlights includes: (1) OPG publishes updated professional deputy costs for England and Wales and updated property and financial affairs guidance for attorneys; (2) the Law Commission launches a consultation on a new regulatory framework for funerary methods; (3) HMRC updates its guidance on VAT and private schools; (4) Jusan Technologies Ltd v Uconinvest Llc, which considers the registration of shareholders and the power of directors to bind a company; (5) New Supplemental Swiss Rules for Trust, Estate and Foundation Disputes which will come into force on 1 July 2025; (6) analysis of HNW Lending Ltd v Lawrence, which provides useful guidance on the application of the Contracts (Rights of Third Parties) Act 1999; and (7) two more free webinars.

Private Client weekly highlights—29 May 2025

This week’s edition of Private Client highlights includes: (1) the necessity of a DOLs order where all parties with parental responsibility consent (J (through his Children's Guardian) v Bath and North East Somerset Council); (2) the OPG updates Mental Capacity Act 2005 guidance with new contact details; (3) the FTT cautions on time-wasting use of AI while upholding an HMRC discovery assessment (Zzaman v HMRC); (4) a decision on the suitability of summary judgment for a claim concerning the imposition of a secret trust (Lorenz v Caruana); (5) the FTT upholds a transfer of assets abroad charge in respect of receipt of rent-free accommodation (Moran v HMRC); (6) the Master of the Rolls delivers a speech on AI and Article 6 ECHR; and (7) a free webinar: Court of Protection update.

Read the latest 13 News articles on Disclosure of tax avoidance schemes (DOTAS)