Commentary

A7.206 Notifiable proposals

Administration and compliance

A7.206 Notifiable proposals

A7.206 Notifiable proposals

The disclosure rules are not restricted to schemes which are actually implemented, but also apply to notifiable proposals. This represents a significant widening of the DOTAS principles to, essentially, marketing of anti-avoidance schemes and arrangements. A 'notifiable proposal' is any proposal for arrangements which, if entered into, would be notifiable arrangements regardless of whether the proposal relates to a particular person or just to any person who might take advantage of it1.

This means that notification of schemes made available for implementation, ie taken to market, is also required. HMRC's guidance on the meaning of 'made available for

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