As part of its drive to get to grips with the budget deficit, the coalition government has clearly decided to continue the crackdown begun by their predecessors on so-called ‘tax avoidance schemes’.

In June’s ‘emergency’ budget, the coalition signalled its intention to continue the extension of the ‘disclosure of tax avoidance scheme regime’ (DOTAS) to inheritance tax (IHT) schemes.

The DOTAS regime, introduced in the Finance Act 2004 (FA), currently applies to schemes for the avoidance of income tax, corporation tax, capital gains tax, stamp duty land tax and national insurance contributions. Under the current legislation, a ‘scheme’ consists of an arrangement or plan falling within certain descriptions, under which a ‘tax ...

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