HMRC loses big avoidance case

[phil@pmtc]

Forgive what is possibly a dumb question, but did HMRC not need to know about the scheme for it to have a DOTAS number in the first place ?

Not dumb at all - yes they would. However doesn’t necessarily mean they had everything required. As general rule of thumb though, yes quoting the dotas number on a return is a good argument that they had the info. It isn’t however a certainty.

My point overall though is simply that s29 really is complex and an absolute pain at times, even though it shouldn’t be.