"Following consultation, the March 2010 budget announced a package of five measures to strengthen and improve the Disclosure of Tax Avoidance Schemes (DOTAS) regime. Briefly these measures are:
- A new 'trigger point ' for the disclosure of actively marketed schemes – the point at which a promoter first communicates information (including information about the expected tax advantage) about a substantially designed scheme to a third party with a view to obtaining clients for that scheme;
- An information power which gives HMRC the power to require a scheme 'introducer' (an intermediary whose function is to introduce clients to the promoter) to identify the promoter;
- Increased penalties for failure to comply with a disclosure obligation;
- A new requirement for promoters to provide HMRC with periodic information about clients who implement a notifiable scheme; and
- Revised and extended 'hallmarks' (descriptions of schemes requiring disclosure).
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