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Interesting DoTAS case

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

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: http://financeandtax.decisions.tribunals.gov.uk/judgmentfiles/j10084/TC0...

 

 

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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:

http://www.taxresearch.org.uk/Blog/2012/07/13/how-to-cheat-at-tax-one-en...

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