Commentary

A7.212 In-house schemes—arrangements not involving a promoter

Administration and compliance

A7.212 In-house schemes—arrangements not involving a promoter

A7.212 In-house schemes—arrangements not involving a promoter

Where there is no promoter, any person who enters into a transaction forming part of notifiable arrangements must make a disclosure1. This rule will catch in-house tax planning departments which devise tax schemes and arrangements which could easily fall within the scope of the rules, albeit innocently, eg where the tax team designs a bespoke scheme for its own organisation which it might consider to be tax efficient rather than tax avoidance. Nevertheless there will be an obligation on the company to disclose under DOTAS unless the exemptions apply. Notification is

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