Disclosure of tax avoidance schemes

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FORTHCOMING CHANGES: At Budget 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. The measures are contained in Part 6 of the Bill (as introduced on 4 December 2025) and include:

  1. •

    updates to the DOTAS and DASVOIT civil penalty regime so that HMRC may directly issue DOTAS penalties instead of seeking tribunal approval

  2. •

    a general prohibition on promoting marketed arrangements that have no realistic prospect of success and a prohibition on promoting arrangements specified in universal stop regulations (USRs). A breach of either prohibition would attract a range of sanctions which would include publication, financial penalties and criminal prosecution

  3. •

    promoter action notices (PAN). A PAN would require businesses to stop providing goods or services to promoters of tax avoidance where those goods or services are used in the promotion of avoidance and the promoter is in breach of a USR or stop notice. PANs will primarily be issued to financial institutions, insurance companies, and social media

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Latest Tax News

Tax weekly highlights—11 December 2025

This week's edition of Tax weekly highlights includes: (1) News Analysis on the new measures contained in Finance Bill 2026 (FB 2026) to tackle the promotion of marketed tax avoidance schemes, (2) News Analysis on publication of the Final Report of the independent review of the Loan Charge and the government’s response to that Report, (3) News Analysis on the FB 2026 measure that provides an SDRT relief for new UK listings, (4) News Analysis on the FTT’s refusal to allow amortisation deductions for goodwill created by a predecessor partnership in County Insurance Services Ltd v HMRC, and (5) News Analysis on the FTT’s finding that mixed-use SDLT rates applied to the acquisition of an apartment with a basement storage unit in Sehgal v HMRC.

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Finance Bill 2026—Loan charge review: Final Report and government response

Tax analysis: The Final Report of the independent review of the Loan Charge, together with the government’s response to the Final Report, were both published at Budget 2025, with Finance Bill 2026 containing provisions in respect of the accepted recommendations. Jackelyn West, a senior associate in Macfarlanes’ tax disputes team, sets out the key outcomes of the Final Report and government response below.

Finance Bill 2026—Closing in on promoters of tax avoidance schemes

Tax analysis: The government is legislating in Finance Bill 2026 for new measures to tackle the promotion of marketed tax avoidance schemes. Abigail McGregor and Ian Robotham, Legal Directors in Pinsent Masons’ Contentious Tax team, analyse the measures and consider their practical consequences.

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