Disclosure of tax avoidance schemes—procedure
Disclosure of tax avoidance schemes—procedure

The following Tax practice note provides comprehensive and up to date legal information covering:

  • Disclosure of tax avoidance schemes—procedure
  • Time limits for promoters
  • Time limits for taxpayers
  • How to make a disclosure
  • Scheme reference numbers
  • Schemes used by employers
  • Client lists
  • Information powers
  • Naming and shaming of promoters
  • Penalties
  • More...

FORTHCOMING CHANGE relating to Finance Bill 2021: Finance Bill 2021 (FB 2021) introduces a new information notice that HMRC may issue to anyone it suspects of being involved in the supply of arrangements that should have been disclosed, and a power for HMRC to issue a scheme reference number if the requested information is not forthcoming. The change will apply from Royal Assent to FB 2021, and draft technical guidance was published on 23 March 2021. For more information on the FB 2021 provisions, see News Analysis: Spring Budget 2021—Tax analysis—Tackling promoters of tax avoidance, and for information on the draft clauses that were published in July 2020, see News Analysis: Draft Finance Bill 2020–21—promoters and enablers of tax avoidance schemes.

FORTHCOMING CHANGE relating to Finance Bill 2021–22: The government intends to introduce further measures to counter promoters of tax avoidance schemes in the Finance Bill 2021–22 (which is expected to be enacted as the Finance Act 2022). The measures include a new power for HMRC to freeze a promoter’s assets, penalties for UK entities that support offshore promoters, and another new power for HMRC to apply to wind up companies that promote tax avoidance and to disqualify the directors. For more information, see News Analysis: Tax consultation day—23 March 2021—Clamping down on promoters of tax avoidance.

This Practice Note covers the procedural aspects of the

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