A7.244 DOTAS—incomplete disclosure by the promoter
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 discusses the action HMRC can take if the disclosure received from the promoter in relation to notifiable proposals/arrangements is incomplete (ie contains insufficient information). For the action that HMRC can take in relation to an incomplete disclosure by the scheme user, see A7.246.
For an overview of the information powers that can be used by HMRC in relation to DOTAS, see A7.240.
For the definition of notifiable arrangements and proposals, see A7.205–A7.206.
Incomplete disclosure by the promoter
Under DOTAS, the onus is on the promoter to provide a full explanation of the proposal/arrangements