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DOTAS
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DOTAS
DOTAS
DOTAS: ‘tax advantage’ and counterfactuals in Hallmark 5
Kyle Rainsford
Kyle Rainsford (Addleshaw Goddard) examines the Property 118 decision and the questions it raises about tax advantages, comparator transactions and the purpose tests in DOTAS Hallmark 5.
Freedom (of information) is a noble thing: HMRC, tax and the limits of transparency
Hartley Foster
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.
Closing in on promoters of marketed tax avoidance scheme
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.
Property 118 Ltd and another v HMRC
Appeal allowed against HMRC allocating scheme reference numbers under DOTAS
Other cases that caught our eye: 17 April 2026
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...
HMRC v A O’Brien
FTT applies
Rangers
to contractor loan scheme and rejects s 29 defence
AD Bly Groundworks and Civil Engineering Ltd v HMRC
No deduction allowable for provisions in respect of an unfunded unapproved retirement benefit scheme, Court of Appeal rules
HMRC v Industria Umbrella Ltd (In liquidation)
FTT imposes maximum £1m DOTAS penalty for failure to notify
B Lynch v HMRC
Ramsay
argument fails to save taxpayer from £10m tax assessment
HMRC v Asset House Piccadilly Ltd
FTT considers meaning of ‘promoter’ in DOTAS regime.
Go to page
of
5
EDITOR'S PICK
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
1 /7
The Orsted ‘tax nothing’
Andrew Page
2 /7
Budget 2026: options for taxing wealth
Dom Rothbarth
3 /7
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
,
Craig Kirkham-Wilson
4 /7
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
5 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
6 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
7 /7
Budget 2026: protecting the UK’s tax competitiveness
David Gordon
The Orsted ‘tax nothing’
Andrew Page
Budget 2026: options for taxing wealth
Dom Rothbarth
HMRC powers and the taxpayer relationship: when is enough, enough?
Chris Sanger
,
Constantine Christofi
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
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Budget capital allowances changes: mixed picture for business investment decisions
Government declines to expand land remediation relief
HMRC publish new RTI guidance for employers
ERS: annual returns after scheme closure
CBAM: technical guidance on emissions reporting
CASES
Read all
Abbey Group Ltd v HMRC
Strauss Phillips & Co Ltd v HMRC
Education Training Collective v HMRC
Other cases that caught our eye: 30 October 2026
ScottishPower (SCPL) Ltd and others v HMRC
IN BRIEF
Read all
AI and the unwinnable case
Corporate residence: beyond the paperwork
Hill: the Upper Tribunal on reasonable excuse
Loans to participators: s 455
Modernising the taxation of distributions
MOST READ
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The Nigel Blackwell Family Trust and others v HMRC
One minute with... Helen Miller
Chancellor reportedly rejects alignment of CGT and income tax rates
ScottishPower (SCPL) Ltd and others v HMRC
Side-by-Side: four scenarios for 2030