DOTAS

Ramsay argument fails to save taxpayer from £10m tax assessment  

FTT considers meaning of ‘promoter’ in DOTAS regime.

Interest calculation on restitutionary payment: Test claimants in the franked investment income group litigation v HMRC [2024] EWHC 1671 (Ch) (18 June 2024) is another episode in the saga of the compatibility of the UK’s regime for the taxation...

Andrew Parkes (Andersen) considers the limits, if any, on the introduction of retrospective legislation.

Discovery assessment on pension scheme charges upheld: L Trachtenberg v HMRC [2024] UKFTT 376 (TC) (9 May) involves another challenge to the scope of the discovery provisions, this time concerning pension scheme unauthorised payments charges...

Costs decision reversed: Metropolitan International Schools Ltd v HMRC [2024] UKFTT 320 (TC) (10 April 2024) is a slightly odd decision where a FTT judge reversed her own decision about an award of costs against HMRC. The details are probably of...

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

FTT imposed £900,000 penalty for six-year late DOTAS disclosure.

Hyrax and Curzon Capital Ltd consider for the first time the provisions governing HMRC’s ability to seek an order that a scheme is notifiable under DOTAS. Lee Ellis and Cristiana Bulbuc (Stewarts Law) consider the practical implications.