Consultation outcome

Tackling marketed tax avoidance

This consultation has concluded

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Detail of outcome

Following consultation, the Government announced at Budget 2014 its intention to require tax payers to pay upfront any disputed tax in avoidance cases that have been notified to HMRC through the Disclosure of Tax Avoidance Scheme (DOTAS) rules, or counteracted by the General Anti-Abuse Rule (GAAR).

This is an extension to the measure announced at Autumn Statement to issue accelerated payment notices to taxpayers in situations where another user’s arrangement, which is the same or very similar, has been defeated in the courts. The Government will introduce legislation to implement these policies in the Finance Bill. This document summarises the responses to the consultation, the Government’s position in light of the responses, and further information about the delivery of this policy and some examples where it would apply.

If you are worried you may be caught up in one of the avoidance schemes within these policies, speak to your adviser or call our dedicated contact point on 03000 530 435.

Those who are considering engaging in tax avoidance can visit for further information and advice.

Read about some of the tax avoidance schemes that HMRC thinks you should be aware of:

Original consultation

This consultation ran from 24 January 2014 3:00pm to
24 February 2014 11:45pm


This consultation sets out proposals to tackle tax avoidance by changing the economics of devising and entering into tax avoidance schemes.


Tackling marketed tax avoidance

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Consultation description

This consultation sets out the Government’s legislative proposals to change the economic incentives to avoid tax by requiring those using avoidance schemes to pay upfront and give them an incentive to resolve avoidance disputes as soon as possible. The Government announced at Autumn Statement 2013 that it would take forward its proposals regarding High Risk Promoters and ‘follower notices’, that it would introduce an accelerated payments measure linked to the issue of a ‘follower notice’, and that it would consult on widening the criteria for seeking accelerated payment during avoidance disputes. This consultation sets out draft legislation to implement the measures announced at Autumn Statement, and consultation proposals for the wider criteria.