Readers’ forum: Artificial tax planning arrangement

I am preparing a client’s tax return. The client has just told me that she entered into a tax planning arrangement which was promoted by another firm. I had no involvement with the scheme and the first I knew of it was when she sent me a schedule provided by the scheme promoter showing the entries which should be made on the return.

I have not seen any of the underlying documents but from the schedule which has been provided it seems the scheme was highly complex and completely artificial. However the client has not been provided with a disclosure of tax avoidance schemes (DOTAS) reference number.

I queried that with her and she says the promoter has said that counsel has advised that the scheme does not need to be notified under DOTAS. I have not seen that advice.

Everything I have seen suggests that this...