Stephen Pevsner (King & Wood Mallesons) examines the new financial products hallmark introduced into the DOTAS rules in February. Are concerns over their scope overstated?
Ever since its introduction in FA 2004 there have been discussions about the scope of the disclosure of tax avoidance schemes (DOTAS) provisions contained in FA 2004 Part 7 and the related secondary legislation with the relevant ‘hallmarks’ the extent of information available to HMRC the penalties and the consequences of use being extended a number of times. The general view has been that the legislation is aimed at what are broadly aggressive tax avoidance arrangements rather than at ordinary tax planning or structuring commercial transactions to fall within the scope of available reliefs or exemptions.
Concern has however recently been raised amongst advisers about the introduction of the new ‘financial products hallmark’ by the Tax Avoidance...
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Stephen Pevsner (King & Wood Mallesons) examines the new financial products hallmark introduced into the DOTAS rules in February. Are concerns over their scope overstated?
Ever since its introduction in FA 2004 there have been discussions about the scope of the disclosure of tax avoidance schemes (DOTAS) provisions contained in FA 2004 Part 7 and the related secondary legislation with the relevant ‘hallmarks’ the extent of information available to HMRC the penalties and the consequences of use being extended a number of times. The general view has been that the legislation is aimed at what are broadly aggressive tax avoidance arrangements rather than at ordinary tax planning or structuring commercial transactions to fall within the scope of available reliefs or exemptions.
Concern has however recently been raised amongst advisers about the introduction of the new ‘financial products hallmark’ by the Tax Avoidance...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
