Disclosure of tax avoidance schemes

FORTHCOMING CHANGE: At Budget 2025 on 26 November 2025, the government announced that it will legislate in Finance Bill 2026 (also known as Finance (No 2) Bill 2024–26) to introduce measures targeting promoters or enablers of marketed tax avoidance. For more information, see News Analysis: Budget 2025—Private Client analysis — Tax avoidance, evasion and non-compliance.

The rules on the disclosure of tax avoidance schemes (DOTAS) (and their indirect tax equivalent, disclosure of tax avoidance schemes for VAT and other indirect taxes (DASVOIT)) oblige tax advisers, or sometimes the taxpayer, to inform HMRC about certain arrangements avoiding UK taxes. Further rules require the disclosure of certain cross-border arrangements to avoid obligations to report information on financial accounts and beneficial ownership. Initially these rules were contained in legislation implementing the EU directive known as DAC 6, but these were replaced by legislation to implement the OECD Mandatory Disclosure Rules (MDR) applicable to arrangements entered into on or after 28 March 2023.

For more information on the MDR, see Practice Note: Disclosable cross-border tax arrangements—Mandatory Disclosure Rules (MDR) and below.

Making

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