Policy paper

Closing in on promoters of marketed tax avoidance

Published 21 July 2025

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This publication is available at https://www.gov.uk/government/publications/proposals-to-close-in-on-promoters-of-marketed-tax-avoidance/closing-in-on-promoters-of-marketed-tax-avoidance

Who is likely to be affected

Promoters of marketed tax avoidance schemes, and other professionals who market or enable the marketing of tax avoidance schemes, including within the tax, accounting and legal professions, are likely to be affected by these measures. Business that provide services to those promoters and other professionals will also be affected by some of the new measures. These companies would include providers of financial services such as banking and insurance and social media or technology companies.

General description of the measures

These measures will make a number of changes to the current legislation that targets those who promote or enable marketed tax avoidance.

Disclosure of tax avoidance schemes (DOTAS)

They will introduce:

  • a criminal offence for the failure of a promoter of tax avoidance arrangements to notify arrangements to HMRC
  • update the DOTAS civil penalty regime so that HMRC may directly issue DOTAS penalties instead of seeking tribunal approval

DOTAS is an information disclosure regime that requires promoters of tax avoidance schemes to provide information about notifiable tax arrangements.

Disclosure of tax avoidance schemes for VAT and other indirect taxes (DASVOIT)

They will introduce:

  • a criminal offence for the failure of a promoter of tax avoidance arrangements to notify arrangements to HMRC
  • update the DASVOIT civil penalty regime so that HMRC may directly issue DASVOIT penalties instead of seeking tribunal approval

DASVOIT is an information disclosure regime that requires promoters of tax avoidance schemes to provide information about notifiable indirect tax arrangements.

Universal stop notices

They will introduce universal stop notices (USNs). A USN would apply to all promoters and enablers of marketed tax avoidance and prohibit the promotion of the avoidance arrangements set out in the USN. USNs will be issued using secondary legislation (regulations) which will specify details of the arrangements that may not be promoted. A breach of a USN would attract a range of sanctions which would include publication, financial penalties and criminal prosecution.

Promoter action notices

They will introduce promoter action notices (PANs). A PAN would require businesses to stop providing products or services to promoters and enablers of tax avoidance where those products or services are connected to the promotion of avoidance and HMRC suspects the promoter or enabler is in breach of a USN or Stop Notice.

PANs would not apply to legal services where legitimate legal or tax advice is provided. Failure to comply with a PAN would attract a range of sanctions including publication, financial penalties and reporting businesses to relevant representative bodies or regulators.

Connected parties information notice

They will introduce a targeted connected parties information notice (CPIN) which would enable HMRC to issue notices that compel or require persons that HMRC reasonably suspects are connected to the promotion of a marketed tax avoidance scheme to provide relevant information including documents.

This would:

  • expand HMRC’s ability to assess compliance with obligations under HMRC’s existing and proposed anti-avoidance powers
  • support HMRC in effectively investigating those who own and control promoter organisations

Promoter financial information notice

They will introduce a promoter financial information notice (PFIN). A PFIN would allow HMRC to obtain access, with tribunal approval, to financial or banking data relating to promoters and parties connected to the promotion of avoidance held by financial institutions.

They will widen the scope of existing powers to ensure that HMRC can take targeted action against the small number of legal professionals that facilitate the promotion of avoidance schemes, by allowing the publication of legal professionals’ details under certain additional circumstances.

Policy objective

The actions of promoters of marketed tax avoidance facilitate non-compliance and contribute to the tax gap. These efforts to game the system generate no additional value for the economy and deprive vital public services of funding. The government’s intent is to make a step change in efforts to close in on the small number of remaining promoters of tax avoidance. This would contribute to closing the tax gap attributable to marketed tax avoidance.

Background to the measure

The government announced at Autumn Budget 2024 that it would consult on these measures. A 12-week public consultation was launched at the Spring Statement 2025, and the consultation closed on 18 June 2025. The government has included these measures in the draft Finance Bill 2025.

Detailed proposal

Operative date

The proposals will have effect on or after the Royal Assent to the Finance Bill that follows their consideration in Parliament.

Current law

DOTAS

Related current law includes part 7 of the Finance Act (FA) 2004 and section 98C of the Taxes Management Act 1970 (TMA).

DASVOIT

Related current law includes section 66 of and schedule 17 to F(No.2)A 2017, (Indirect Taxes (Disclosure of Avoidance Schemes)), Regulations 2017 (SI 2017/1215) and Indirect Taxes (Notifiable Arrangements) Regulations 2017 (SI 2017/1216).

USNs

The legislation for stop notices is at sections 236A-K in part 5 of Finance Act (FA) 2014. Related legislation includes part 10 of TMA and section 86 of FA 2022.

Promoter action notices

This will be a new power. The legislation is likely to interact with a number of existing legislative regimes including:

  • part 7 of FA 2004 (DOTAS)
  • part 5 of FA 2014 (Promoters of Tax Avoidance schemes)
  • schedule 16 to F(No.2)A 2017 (Enablers of Tax Avoidance schemes)
  • section 86 of FA 2022 (publication by HMRC of information about tax avoidance schemes)
  • section 85 of FA 2022 (winding up petitions by an officer of HMRC)
  • schedule 13 to FA 2024 (director disqualification)
  • schedule 13 to FA 2022 (penalties for facilitating avoidance schemes involving non-resident promoters)
  • section 87 of FA 2022 (freezing orders)

Connected parties information notice

This will be a new power. It is likely to interact with existing legislative regimes including part 5 of FA 2014.

Promoter financial institution notice

This will be a new power. It will operate in a similar way to a financial institution notice (FIN). The legislation for FINs is in part 1 of schedule 36 to FA 2008.

Related legislation includes:

  • part 7 of FA 2004, particularly sections 307-308, 310-311, 314 and 316C (DOTAS)
  • schedule 17 to F(No.2)A 2017 (DASVOIT)
  • section 86 of FA 2022 (publication of information about avoidance schemes)
  • schedule 16 to F(No.2)A 2017 (Enablers of Tax Avoidance schemes).

Proposed revisions

DOTAS

Proposed changes include amendments to introduce a strict liability criminal offence of failing to notify arrangements to HMRC and changes to the penalty provisions to allow HMRC to issue penalties directly.

DASVOIT

Proposed changes include amendments to introduce a strict liability criminal offence of failing to notify arrangements to HMRC and changes to the penalty provisions to allow HMRC to issue penalties directly.

Universal stop notices

Proposed changes include: new legislation setting out how USNs will work and a new power to make regulations to prohibit promotion of described schemes, new financial penalties, publication powers, which will mirror section 86 of FA 2022 and a new criminal offence.

Promoter action notices

Proposed changes include:

  • how PANs will work
  • a new publishing power
  • new information sharing provisions
  • new penalties
  • a new power to report failures to appropriate representative bodies or regulators

A suspected breach of a USN or failure to comply with a stop notice would enable HMRC to issue a PAN.

Connected parties information notice

The new CPIN aims to ensure HMRC can:

  • obtain information that would help it understand the operation of avoidance schemes at an early stage
  • deploy, monitor and enforce compliance with existing and proposed anti-avoidance powers addressing promotion activities
  • identify persons behind promoter group structures and take action against them

Promoter financial institution notice

The new PFIN will allow HMRC to obtain information and documents from financial institutions for the purposes of checking the activities of a promoter and connected parties related to the promotion of an avoidance scheme or schemes. The legislation will largely reflect the current FIN powers in schedule 36 to FAA 2008, with some modifications reflecting the purpose of allowing enquiry into promoter activities.

Proposed changes include amendments to the various publishing sections in legislation, contained at:

  • section 86 of FA 2022
  • section of 316C FA 2004
  • paragraph 36 of schedule 17 to F(No.2)A 2017.

This will be to effectively repeal current sections that restrict publication of the details of legal professionals. The legislation will also set out appropriate safeguards.

Summary of impacts

Exchequer impact (£ million)

2024 to 2025 2025 to 2026 2026 to 2027 2027 to 2028 2028 to 2029 2029 to 2030
Empty Empty Empty Empty Empty Empty

The final costing will be subject to scrutiny by the Office for Budget Responsibility and will be set out at the next fiscal event.

Economic impact

These measures are not expected to have any significant macroeconomic impacts.

Impact on individuals, households and families

These measures are unlikely to have an impact on individuals. However HMRC will continue to assess the impacts of these measures while they are being developed and will provide any updates in the future. They are not expected to impact on family formation, stability and breakdown.

These measures are expected overall to have no impact on individuals’ experience of dealing with HMRC.

Equalities impacts

It is not anticipated that there will be disproportionate impacts on those in groups sharing protected characteristics.

Impact on business including civil society organisations

These measures may have a negligible impact on compliant businesses. HMRC is working to understand these impacts better and will provide updates at future fiscal events.

These measures are not expected to impact civil society organisations.

These measures are expected overall to have no impact on businesses’ experience of dealing with HMRC.

Operational impact (£ million) (HMRC or other)

HMRC will incur some operational costs implementing these changes. These costs are currently being quantified. There may also be increased costs to HM Courts and Tribunal Service. HMRC will work with the Ministry of Justice to assess the potential costs.

Other impacts

A Data Protection Impact Assessment will be completed before the measures are implemented. Other potential impacts have been considered and none have been identified.

Monitoring and evaluation

These measures will be monitored through HMRC operational oversight and feedback from stakeholders.

Further Advice

If you have any questions about this change, email the Counter-Avoidance Policy and Technical team at ca.consultation@hmrc.gov.uk

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