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DOTAS


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.
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 (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.
Appeal allowed against HMRC allocating scheme reference numbers under DOTAS
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.
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