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Under the disclosure of tax avoidance scheme (DOTAS) regime, persons have to self assess tax planning proposals or arrangements, and if these meet one or more ‘hallmarks’ they must be disclosed to HMRC.

The DOTAS regime is deliberately cast quite widely so that it is capable of applying both to something that everyone would recognise as a tax avoidance scheme and to any set of arrangements that may be expected to deliver a tax or national insurance advantage as a main benefit.

The DOTAS rules do not include a definition of an avoidance scheme, instead they focus on whether a scheme is ‘notifiable’. A scheme can be something that it is described as such, but the rules apply equally to any arrangements. This guidance note uses the term ‘scheme’ to cover both. For help in deciding whether a scheme is notifiable in relation to the various taxes, see the DOTAS ― what is a notifiable scheme? guidance note.

This guidance note considers the action which end users of the scheme must take. Although