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The scope of the Disclosure of Tax Avoidance Scheme (DOTAS) Rules (HMRC v Curzon Capital Limited)

The scope of the Disclosure of Tax Avoidance Scheme (DOTAS) Rules (HMRC v Curzon Capital Limited)
Published on: 05 February 2019
Published by: LexisPSL
  • 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

Article summary

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. or take a trial to read the full analysis.

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