Finance Act 2014 (FA 2014) contains rules relating to promoters of tax avoidance schemes (POTAS). These rules are designed to discourage the marketing of tax avoidance schemes by imposing sanctions on promoters who engage in some defined types of behaviour. The POTAS rules were originally referred to in regulations and HMRC guidance as the rules on 'high-risk promoters'.

The POTAS rules build upon the rules for the disclosure of tax avoidance schemes (DOTAS) and use many of the same definitions. This Practice Note is therefore intended to be read together with Practice Note: Disclosure of tax avoidance schemes—income tax, corporation tax, CGT and NICs. The POTAS rules have a separate function from DOTAS, in that DOTAS is designed to elicit information about schemes (and ties in with the rules on accelerated payment notices), while POTAS is intended to impose sanctions on promoters.

This Practice Note is about the POTAS rules in FA 2014, and therefore references to POTAS in this Practice Note mean the rules in that Act. There are a range of other statutory provisions