Changes to DOTAS rules

16 December 2010

A package of measures are introduced from 1 January 2011 to strengthen the disclosure of tax avoidance schemes rules. Broadly, the measures are as follows:


  • Measure 1 – a change to the trigger point for disclosure of marketed schemes to ensure early disclosure of schemes
  • Measure 2 – an information power to allow HM Revenue & Customs to require intermediaries in the marketing of schemes to provide information leading to the identification of the promoter
  • Measure 3 – enhanced penalties for failure to comply with a disclosure obligation
  • Measure 4 – a requirement for promoters to provide periodic lists of clients who have implemented schemes

Guidance on the changes haas been published on the HMRC website, together with a summary of the legislation given statutory effect to the changes.

Similar changes also apply for NIC purposes.


  • Measure 5 – revised hallmarks (the descriptions of schemes requiring disclosure)