Disclosure of Tax Avoidance Schemes (DOTAS) Regime and the Annual Tax on Envolped Dwellings (ATED) - CIOT comments
CIOT comments, sent to HMRC 21 August 2013, regarding the draft regulations.
HMRC consulted on the extension of DOTAS to require the disclosure of certain schemes seeking to avoid ATED. HMRC published a technical note and draft regulations setting out the descriptions of schemes to be disclosed and the information and time limits for doing so.
The technical note (attached) includes:
- Draft regulations: The Annual Tax on Enveloped Dwellings Avoidance Schemes( Prescribed Descriptions of Arrangements ) Regulations 2013 setting out the types of scheme requiring disclosure ( widely defined but with an exemption for excluded arrangements) (Is regulation 3 - the transitional provisions a concern?)
- Draft regulations: The Tax Avoidance Schemes (Information) (Amendment) Regulations 2013 specifying the information requirements and time limits.
- New form AAG4(ATED)
- A link to the revised TIN to reflect the impact of ATED being brought within the scope of DOTAS. The revised TIN is attached.
Our submission and the TIN/explanatory note are attached below in Adobe (PDF) format.
21 August 2013