A7.234 DOTAS—duty to provide clients lists to HMRC
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 obligation on promoters and others to provide client lists to HMRC after the issue of a scheme reference number in relation to the proposal/arrangements. For details of the other obligations that follow the issue of the scheme reference number, see A7.233.
For details of who should make the disclosure under DOTAS and the deadline for doing so, see A7.230–A7.231.
For the definition of notifiable proposals and notifiable arrangements, see A7.205–A7.206.
Duty to provide clients lists to HMRC
HMRC will issue a scheme reference number (SRN) in the following circumstances:
• where there has been a disclosure of the proposal/arrangements by a promoter or scheme user. This is known as a subsection (2) case (see A7.230), or
• where HMRC suspects that the proposal/arrangements are