Originally posted by LisaContractorUmbrella
					
						
						
							
							
							
							
								
								
								
								
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		"Schemes that promoters know to be known to HMRC are not caught by the hallmark. These can be evidenced from, for example, technical guidance notes, case law, or past correspondence with a case officer in HMRC where the detail of how the scheme works has been made clear."
http://www.hmrc.gov.uk/aiu/dotas.pdf
Clearly the Dextra and Sempra litigation is known to HMRC.
					Originally posted by LisaContractorUmbrella
					
						
						
							
							
							
							
								
								
								
								
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