- FTT decides arrangements were notifiable under DOTAS (HMRC v Smartpay Ltd)
- Why it matters
- Case details
Tax analysis: In Smartpay, the First-tier Tax Tribunal (FTT) granted HMRC’s application under the DOTAS provisions (section 314A of the Finance Act 2004 (FA 2004)), holding that the arrangements in question were ‘notifiable arrangements’ and that both of the companies which were the subject of the application were promoters of them.
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