DOTAS

Hartley Foster (Addington Chambers) examines the right to obtain information from public authorities such as HMRC, via the Freedom of Information Act 2000, and the restrictions on that right.

Malcolm Gammie CBE KC

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.

Share loss relief: S Wilders v HMRC [2026] UKFTT 517 (TC) (1 April) is a claim for share loss relief arising from a failed attempt to recover treasure from the wreck of the ship the Merchant Royal, which sunk in 1641 off Land’s End. Investors...

FTT applies Rangers to contractor loan scheme and rejects s 29 defence

No deduction allowable for provisions in respect of an unfunded unapproved retirement benefit scheme, Court of Appeal rules

FTT imposes maximum £1m DOTAS penalty for failure to notify

Ramsay argument fails to save taxpayer from £10m tax assessment

FTT considers meaning of ‘promoter’ in DOTAS regime.

Interest calculation on restitutionary payment: Test claimants in the franked investment income group litigation v HMRC [2024] EWHC 1671 (Ch) (18 June 2024) is another episode in the saga of the compatibility of the UK’s regime for the taxation...