Arrangements were notifiable under DOTAS

The hearing was to consider HMRC’s application for the First-tier Tribunal to make an order that arrangements were notifiable under the disclosure of tax avoidance schemes regime (FA 2004 s 306(1))

Under the arrangements individuals became partners in a partnership of which an Isle of Man company I Ltd was the managing partner. The participants’ services were supplied to third parties and they received drawings from the partnership and a loans from the Isle of Man company in the form of a loan. The money from loans could be up to 85% of the total sums received and the taxpayer said the loans would never have to be repaid. The participants did not include the loans in their tax returns.

No representative of the taxpayer attended the hearing but its remaining director provided a witness statement in which he asserted the company’s role in the arrangements...