FTT imposes maximum £1m DOTAS penalty for failure to notify
In HMRC v Industria Umbrella Ltd (In liquidation) [2025] UKFTT 494 (TC) (30 April) the First-tier Tribunal (FTT) held that when considering the quantum of a penalty for the failure to notify arrangements under the disclosure of tax avoidance schemes (DOTAS) rules the amount determined by the daily penalty calculation was insufficient holding instead that the maximum £1m penalty was necessary. The FTT noted that the fees charged by the promoter were high-level and given the question of whether the arrangements were notifiable was not complex there was no reason for non-compliance.
HMRC submitted that Industria Umbrella had promoted contractor loan schemes which were designed to enable contractors to receive most of their gross contract value in the form of ‘loans’ and only a small portion as salary paid via PAYE.
HMRC had explained to...
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FTT imposes maximum £1m DOTAS penalty for failure to notify
In HMRC v Industria Umbrella Ltd (In liquidation) [2025] UKFTT 494 (TC) (30 April) the First-tier Tribunal (FTT) held that when considering the quantum of a penalty for the failure to notify arrangements under the disclosure of tax avoidance schemes (DOTAS) rules the amount determined by the daily penalty calculation was insufficient holding instead that the maximum £1m penalty was necessary. The FTT noted that the fees charged by the promoter were high-level and given the question of whether the arrangements were notifiable was not complex there was no reason for non-compliance.
HMRC submitted that Industria Umbrella had promoted contractor loan schemes which were designed to enable contractors to receive most of their gross contract value in the form of ‘loans’ and only a small portion as salary paid via PAYE.
HMRC had explained to...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
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