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Contentious tax quarterly: Spring 2024 review

We are seeing a flurry of activity from HMRC on DOTAS and on R&D claims, report Adam Craggs and Harry Smith (RPC).

In this quarterly review we consider: (1) recent developments in relation to the Disclosure of Tax Avoidance Schemes (DOTAS) regime; (2) the state of play in relation to R&D reliefs; and (3) some implications of the Economic Crime and Corporate Transparency Act 2023.

DOTAS

The DOTAS regime contained in FA 2004 Part 7 has been around for nearly 20 years and was originally designed to give HMRC a ‘heads-up’ on the mass-marketed tax avoidance products that were prevalent at the time it was introduced. Since then the world has moved on and taxpayers’ appetite for tax avoidance schemes has diminished significantly.

However we have seen a recent flurry of activity from HMRC seeking to require the registration of arrangements under the...

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