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Schemes should be notified under DOTAS

26 April 2022
Issue: 4837 / Categories: Tax cases
CRC v AML Tax (UK) Ltd (TC8445)

HMRC made applications for an order under FA 2004 s 314A that two arrangements were notifiable within the disclosure of tax avoidance schemes (DOTAS) regime.

The first scheme was an annuity arrangement used by close companies. It entailed the use of an option and an annuity agreement to clear the loan accounts of directors/shareholders. The second scheme involved an employee benefit trust (EBT) set up by an Isle of Man company related to AML. An employer company bought the right to appoint beneficiaries to the EBT with the purchase price left outstanding. One or more employees then agreed to assume the company’s obligation to pay the outstanding purchase price and in return an amount previously lent to that individual by the company would be credited.

AML accepted that it was a promoter of the annuity arrangements but denied that it was a promoter of the EBT...

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