HMRC have updated their guidance on the disclosure of tax avoidance schemes (DOTAS) regime to reflect outcomes from recent tribunal decisions and clarify obligations for promoters and suppliers. Key changes include:
para 3.2: discussion of whether a relevant business is being carried on (HMRC v Smartpay Ltd [2022] UKFTT 146 (TC));
para 3.3: analysis of who is an introducer noting that facts of the case are key rather than the subjective view of an individual (HMRC v AML Tax UK Ltd [2022] UKFTT 114 (TC)) – although it is potentially important to note that the words quoted on this point do not actually appear anywhere in the case transcript itself;
para 3.6: making the scheme available for implementation by others – covering points from both of the above decisions including that the person making the proposal available for implementation by others does not need to have been...
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HMRC have updated their guidance on the disclosure of tax avoidance schemes (DOTAS) regime to reflect outcomes from recent tribunal decisions and clarify obligations for promoters and suppliers. Key changes include:
para 3.2: discussion of whether a relevant business is being carried on (HMRC v Smartpay Ltd [2022] UKFTT 146 (TC));
para 3.3: analysis of who is an introducer noting that facts of the case are key rather than the subjective view of an individual (HMRC v AML Tax UK Ltd [2022] UKFTT 114 (TC)) – although it is potentially important to note that the words quoted on this point do not actually appear anywhere in the case transcript itself;
para 3.6: making the scheme available for implementation by others – covering points from both of the above decisions including that the person making the proposal available for implementation by others does not need to have been...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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