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Surefield, White Collar Financial and DOTAS

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    Surefield, White Collar Financial and DOTAS

    Revenue & Customs v White Collar Financial Ltd (DOTAS - Application for order that certain arrangements are notifiable) [2020] UKFTT 459 (TC) (16 March 2020)

    HMRC applied to the Tribunal for a decision that the arrangements used in the Surefield iteration of the White Collar family of schemes, should be regarded as "notifiable" under the DOTAS rules and therefore should have been disclosed.

    In the absence of any defence (or appearance) from any White Collar representative, the Judge clearly spent some time thinking carefully (hearing was October 2018, decision is dated March 2020, released to Baili this week).

    The decision was however that the arrangement was notifiable and should have been disclosed.

    In theory, where you have open enquiries for years in which you used Surefield (also widely known as On Target and/or White Collar) in the years it was active (around April 2011 to March 2015) then HMRC can think about and perhaps issue an APN.

    We have no idea if they will.

    HMRC has previously won a similar case against the Hyrax scheme but has not issued APNs.

    It would entirely inconsistent for one scheme to be targeted and another not and therein may lie a means to resist?

    More likely is that HMRC were awaiting response to loan charge before going ahead with another raft of APNs.
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