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Interesting DoTAS case

To my knowledge the 1st case re forcing a scheme to be notifiable

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The taxpayers will now have a 20 year assessment period. Ouch! At least HMRC did not seek non-disclosure penalties (as the promoter presumably relied on counsel's opinion that it was not disclosable). See:



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By Justin Bryant
21st Sep 2017 16:22

Ouch meaning HMRC can now issue APNs to all the taxpayers involved outside the normal 4 year window (so pre GAAR cases can be netted by HMRC).

The case referred to HMRC making internet searches of the scheme and presumably they found this one from 2012:

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