1 GENERAL NEWS
1.1 DOTAS regulations
Regulations have been published amending the DOTAS regime as
noted below. The changes come into force on 4 November 2013, and
the notes below highlight any transitional rules:
Amendment to confidentiality hallmark and new disguised
remuneration hallmark
SI 2013/2595 applies where on or after 4 November 2013 the
promoter either (i) makes a scheme available to someone, or (ii)
first becomes aware of the existence of a transaction forming part
of the notifiable arrangements and the arrangement has not already
been notified.
Instead of the requirement to disclose being where the promoter
would (but for the regulations) keep confidential from HMRC the
element of the arrangements giving rise to the tax advantage, this
condition is being changed to one where the promoter might
reasonably expect a promoter would keep it confidential from HMRC.
This includes where the promoter does not provide promotional
material to the user or
