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DoTAS penalties toothless against older firms

If you're an old firm with no novel tax planning peddled you're fine

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Old firms are now low risk therefore compared to new firms re potential nasty (and retrospective) DoTAS penalties (effectively a kind of grandfathering). See:

https://financeandtax.decisions.tribunals.gov.uk/judgmentfiles/j12234/TC...

And it's another HMRC c*ck-up of course. The nasty retrospective effect effectively backfired in this case to protect the firm re the penalty issue time limits.

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By Justin Bryant
08th Oct 2021 11:53

In this example, the firm is now incentivised not to disclose, especially if HMRC are not aware of the potential DoTAS issue, since the 6 year time limit is then likely to come to their rescue in due course:

https://www.gov.uk/guidance/joint-and-several-liability-notices-and-pena...

See also Example 2, Situation C here: https://www.gov.uk/guidance/overview-of-joint-and-several-liability-noti...

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