Malcolm Gammie CBE KC (One Essex Court) examines recent Government proposals which, he says, leave little doubt that tax avoidance, like tax evasion, is to be regarded as a criminal activity.
On 26 March 2025 HMRC published for consultation a set of proposals designed ‘to close in on promoters (and other enablers) of tax avoidance schemes’. The document seeks views on proposals in four areas:
Expanding the scope of the Disclosure of Tax Avoidance Schemes (DOTAS) regime;
Introducing a Universal Stop Notice and Promoter Action Notice;
Tackling controlling minds and those behind the promotion of avoidance schemes through new highly targeted obligations and stronger information powers; and
Exploring options to tackle legal professionals designing or contributing to the promotion of avoidance schemes.
The proposals in each of these areas are outlined below to provide the context for the commentary that follows.
DOTAS
Chapter 3 of the document seeks views on three options designed...
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Malcolm Gammie CBE KC (One Essex Court) examines recent Government proposals which, he says, leave little doubt that tax avoidance, like tax evasion, is to be regarded as a criminal activity.
On 26 March 2025 HMRC published for consultation a set of proposals designed ‘to close in on promoters (and other enablers) of tax avoidance schemes’. The document seeks views on proposals in four areas:
Expanding the scope of the Disclosure of Tax Avoidance Schemes (DOTAS) regime;
Introducing a Universal Stop Notice and Promoter Action Notice;
Tackling controlling minds and those behind the promotion of avoidance schemes through new highly targeted obligations and stronger information powers; and
Exploring options to tackle legal professionals designing or contributing to the promotion of avoidance schemes.
The proposals in each of these areas are outlined below to provide the context for the commentary that follows.
DOTAS
Chapter 3 of the document seeks views on three options designed...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
