The existing regime for the disclosure of VAT avoidance schemes (VADR) rarely rears its head in the context of everyday transactions. This is as it should be: why should disclosure be an issue where both HMRC and the taxpayer agree there is no VAT avoidance? However, the same may not be true for the new regime for the disclosure of tax avoidance schemes involving VAT (DOTAS: VAT), to be introduced by the Finance Act 2017. Not only are the new rules significantly more convoluted than the VADR provisions, they also intrude on one of the most common transaction types – the vanilla sale of a let commercial building.
