Originally posted by dangerouswhensober
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https://www.gov.uk/government/upload...DOTAS_GAAR.pdf
Legislation will be introduced in Finance Bill 2014 to enable HMRC to issue a ‘Notice to Pay’
to any taxpayer for whom there is an open enquiry, or the matter is under appeal, and who
has claimed a tax advantage by the use of arrangements that:
• fall to be disclosed under DOTAS, or
• HMRC counteracts under the GAAR following an opinion of the GAAR Advisory Panel
that, in the Panel’s opinion, the arrangements are not a reasonable course of action.
I guess it all depends on what the GAAR Advisory Panel decides for relevant schemes.
Comment