In HMRC v Hyrax Resourcing Ltd [2022] UKFTT 218 (TC) (13 July 2022) the FTT granted HMRC’s application for a penalty to be imposed on the company for its failure to notify notifiable arrangements under the DOTAS rules.
In a previous decision ([2019] UKFTT 175 (TC)) the FTT had held that a loan contractor scheme (the ‘Hyrax arrangements’) constituted notifiable arrangements under the DOTAS rules and that the company was a promoter of those arrangements. HMRC therefore applied to...