Commentary

A7.213 DOTAS—clients: information covered by legal professional privilege

Administration and compliance

A7.213 DOTAS—clients: information covered by legal professional privilege

A7.213 DOTAS—clients: information covered by legal professional privilege

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 requirements for users of a scheme to make the disclosure under DOTAS where the promoter is a lawyer who is prevented from making the

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