Policy paper

Tackling promoters of marketed tax avoidance

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

• From: HM Revenue & Customs
• Published: 26 November 2025

Documents

Closing in on promoters of marketed tax avoidance schemes

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Details

These measures target:

• promoters of marketed tax avoidance schemes
• professionals who market or enable the marketing of tax avoidance schemes

New powers will introduce a:

• ban on promoting avoidance arrangements that have no realistic prospect of success
• power to allow HMRC commissioners to specify further arrangements in regulations which may not be promoted, with penalties and a criminal offence for non-compliance

Instead of applying to the courts, HMRC will now issue :

• disclosure of tax avoidance scheme (DOTAS) penalties
• disclosure of tax avoidance schemes: VAT and other indirect taxes (DASVOIT) penalties

HMRC can also:

• issue promoter action notices (PANs) which require businesses providing goods and services to promoters to stop
• issue anti-avoidance information notices (AAIN) which allow HMRC to effectively investigate promoter organisations and identify the responsible individuals, with penalties and criminal offences for those who are non-compliant
• publish details of legal professionals promoting schemes in more circumstances

Published 26 November 2025