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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
Redrawing the line: modernising the taxation of distributions
Jill Gatehouse
,
Emily Szasz
,
Joe Williams
,
Tom Gardner
1 /7
Reckless tax statements: a lower threshold for crime?
Adam Craggs
,
Tom Jenkins
2 /7
Permanent Establishment exemption: preparing for mandatory application
Alison Lobb
,
Lisa Shipley
3 /7
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
4 /7
The new Securities Transfer Tax: business as usual?
Georgina West
5 /7
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
6 /7
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
,
Lauren Trask
7 /7
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
The 2026 loan charge settlement scheme: the beginning of the end?
David Pett
The new Securities Transfer Tax: business as usual?
Georgina West
Responding to Sch 36 notices: a practical guide
Stephanie Mullins
,
Richard Jeens
Rights, influence and LLP member status after BlueCrest
Constantine Christofi
,
Craig Kirkham-Wilson
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J Scheckter v HMRC
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The Executors of Hunt and others v HMRC
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HMRC get more bang for their buck
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Raising standards without regulating the profession
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HMRC manual changes: 4 September 2026