FTT considers meaning of ‘promoter’ in DOTAS regime.
In HMRC v Asset House Piccadilly Ltd [2025] UKFTT 206 (TC) (12 February) the FTT allowed HMRC’s application and made an order that the arrangements put in place by the respondent AHP were notifiable arrangements within the disclosure of tax avoidance schemes (DOTAS) rules. The FTT rejected AHP’s argument that it was not a ‘promoter’ of the arrangements.
HMRC had applied under of FA 2004 s 314A for an order that the ‘corporate remuneration trust scheme’ arrangements (which allowed directors to extract profits from a company without incurring a charge to income tax due to the provision of loans in place of a reduced salary) put in place by AHP were notifiable arrangements within the meaning of FA 2004 s 306(1). HMRC’s application specified AHP as the ‘promoter’ of the arrangements.
The FTT held that the arrangements...
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FTT considers meaning of ‘promoter’ in DOTAS regime.
In HMRC v Asset House Piccadilly Ltd [2025] UKFTT 206 (TC) (12 February) the FTT allowed HMRC’s application and made an order that the arrangements put in place by the respondent AHP were notifiable arrangements within the disclosure of tax avoidance schemes (DOTAS) rules. The FTT rejected AHP’s argument that it was not a ‘promoter’ of the arrangements.
HMRC had applied under of FA 2004 s 314A for an order that the ‘corporate remuneration trust scheme’ arrangements (which allowed directors to extract profits from a company without incurring a charge to income tax due to the provision of loans in place of a reduced salary) put in place by AHP were notifiable arrangements within the meaning of FA 2004 s 306(1). HMRC’s application specified AHP as the ‘promoter’ of the arrangements.
The FTT held that the arrangements...
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