FA 2010 analysis – DOTAS

Speed Read: FA 2010 s 56 and Sch 17 introduce four measures which will extend the scope of the DOTAS regime and increase penalties for non-compliance, with effect from a date to be appointed (expected to be in Autumn 2010). These are: bringing forward the time of disclosure; quarterly reporting of scheme users; increased HMRC powers to identify promoters; and increased penalties. At the same time as these measures will become effective, it is also likely that the descriptions of direct tax schemes required to be disclosed (the so-called 'hallmarks') will be extended by regulations.