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MICHAEL AVIENT looks at the effect of the disclosure of tax avoidance schemes on HMRC's investigations.
Key points
- The requirement to make early disclosure of schemes.
- The threat of penalties if disclosure is delayed.
- Information may now be required from many involved parties.
- The effect in delaying the making of repayments.
- The relationship between partnerships and partners.
A POWERFUL ARMOURY is now at the disposal of HMRC when it comes to their dealing with marketed tax avoidance schemes. It has been the stated aim of HMRC to reduce the number of such schemes in the market and both the new powers that HMRC have obtained together with a change in strategy have significantly altered the approach to investigations in this area.
The DOTAS effect
The introduction of the rules on disclosure of tax avoidance schemes (DOTAS) in FA 2004 Pt 7 and the subsequent Treasury Regulations...
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