A7.240C DOTAS—notice of potential allocation of reference number—further information required
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 a request by HMRC for further information following the issue of a notice of potential allocation of reference number (a FA 2004, s 310D notice).
Potential allocation of scheme reference number notice
With effect from 10 June 2021, HMRC can issue a FA 2004, s 310D notice where it suspects that arrangements and proposals are notifiable under DOTAS but have not been disclosed to HMRC. For the meaning of notifiable arrangements and notifiable proposals, see A7.205–A7.206.
HMRC can issue the notice to any person it suspects of being involved in the supply of notifiable