- The scope of the Disclosure of Tax Avoidance Scheme (DOTAS) Rules (HMRC v Curzon Capital Limited)
- What are the practical implications of this case?
- What was the background?
- What did the court decide?
- What were the relevant arrangements?
- Were the arrangements ‘notifiable’?
- Was the taxpayer a ‘promoter’?
- Case details
Tax analysis: Disclosure of Tax Avoidance Schemes—the court ruled that a company providing extensive administrative support services for a widely-promoted scheme to avoid employment income tax was not a ‘promoter’ of that scheme. Hence it had no obligations to disclose specified information under the DOTAS rules in Finance Act 2004 (FA 2004), Pt 7, even though the scheme was in principle ‘notifiable’ on more than one ground.
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