Institute welcomes promoters rethink

27 Nov 2025

The Chartered Institute of Taxation has welcomed the government’s decision1 not to introduce a criminal offence of failing to notify a scheme under the Disclosure of Tax Avoidance Scheme (DOTAS) rules.  

The decision was made following consultation with CIOT and other stakeholders on draft legislation published in July 2025. CIOT had argued that the proposals were poorly targeted, imposing potentially unworkable conditions on tax agents, whilst many of the “bad actors” who were the target of the measures are based offshore, so would be out of reach and able to continue their abuse of the system. 

Commenting on the announcement, Ellen Milner, Director of Public Policy at the CIOT, said: 

“This is good news. The proposed offence was too blunt an instrument and needed to be more closely targeted at the 20 to 30 promoters that HMRC say are still active in the tax avoidance market. It is encouraging that HMRC have listened to our concerns, and those of others, and decided not to proceed with this measure.  

“We look forward to supporting HMRC with considering alternative options for tackling these promoters, while not undermining or disrupting the good work of the vast majority of agents.”   

ENDS 

Notes  

  1. Measures to tackle promoters of marketed tax avoidance were published yesterday. They do not include a criminal offence of failing to notify a scheme under DOTAS. 
  2. The CIOT’s comments on the draft Finance Bill measure “Proposals to close in on promoters of tax avoidance”.