HMRC Take Aim at the Users of Nearly 1,200 Tax Avoidance Schemes

HMRC have published a list of tax avoidance schemes for which it wants up-front tax payments.

Two days before the Finance Bill became the Finance Act, the obviously eager HMRC issued a list of nearly 1,200 tax avoidance schemes. Frustratingly the list consisted only of the scheme reference numbers (SRNs), given under the Disclosure of Tax Avoidance Scheme (DOTAS) legislation, so there were none of the exotic names which have been making headlines in some of the national press.

Starting in August, HMRC intend to spend about 20 months using ‘accelerated payment’ powers given to them by the Finance Act 2014 to systematically ask the schemes’ users to pay the tax they thought had been avoided within 90 days. HMRC say that there are approximately 33,000 individual taxpayers and 10,000 companies involved, with over £7bn of revenue at stake.  HMRC have given no indication how they will progress through their long list, although some of the schemes could date back to 2004, when DOTAS was introduced.

Shortly after publishing the DOTAS list, HMRC issued a press release claiming that their High Net Worth Unit had brought in £1bn in “compliance yield”. The Unit, established in 2009, deals with the tax affairs of “the 6,200 wealthiest customers” of HMRC, each with net worth of £20m or more. It seems likely that a fair few of those special customers (sic) will have more opportunities to chat with their HMRC ‘relationship manager’ once the DOTAS list letters roll out begins.

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