A7.206 DOTAS—notifiable proposals
The disclosure of tax avoidance scheme (DOTAS) rules require certain persons, usually promoters of schemes, but also users in certain circumstances, to provide HMRC with information about schemes falling within certain descriptions, known as 'hallmarks'. The person must tell HMRC how the scheme is intended to work, usually within five days of the date the scheme is made available to any person.1
For an overview of the DOTAS regime, see A7.202.
This article considers the meaning of 'notifiable proposals', as the DOTAS regime requires such proposals to be disclosed to HMRC. For the meaning of 'notifiable arrangements', which must also be disclosed to HMRC under DOTAS, see A7.205.
The DOTAS rules are not restricted to schemes that are actually implemented, but also apply to 'notifiable proposals'. A 'notifiable proposal' is any proposal for arrangements which, if