Bequeathing DOTAS

HMRC has published draft regulations which will extend the application of the disclosure of tax avoidance schemes (DOTAS) regime to inheritance tax (IHT) avoidance structures.

The draft regulations set out the circumstances in which arrangements will be required to be registered under the DOTAS regime. Registration will be required where (1) the main purpose (or one of the main purposes) of the arrangement is the obtaining of an IHT advantage; and either (2) it is unlikely somebody would enter into the arrangement but for the advantage; or the arrangement involves one or more contrived or abnormal steps which are required in order to obtain the IHT advantage.

The draft regulations provide for certain exemptions. The closing date for comments on the regulations is 10 September 2015.

The draft regulations can be read here.