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Tax Avoidance Schemes

Over recent years the UK government and HMRC have expended considerable effort in clamping down on what they perceive as tax avoidance.  This has included:

  • Tightening legislation to close potential loopholes that can be exploited;
  • Strengthening the reporting requirements required under the Disclosure of Tax Avoidance (DOTAS) arrangements;
  • Dedicating more resources to take tax avoidance arrangements before the tax tribunals and courts;
  • Increased powers for HMRC, including accelerated payment notices (APNs) and follower notices that require advance payment of tax in a dispute;
  • HMRC using the criminal and fraud investigation powers at their disposal to look at tax avoidance arrangements;
  • Repositioning the debate around tax avoidance in the public's perception.

These increased powers and focus by HMRC make the tax affairs of individuals and companies that have participated in tax avoidance far more open to scrutiny.  This in turn adds to the risk of HMRC considering those tax affairs in depth and can have both financial and reputational repercussions.

How can we help?

Our team at Pinsent Masons has unparalleled experience in helping clients manage the risks associated with tax avoidance and the collective experience to advise on achieving the most appropriate outcome with HMRC.  

We can help in a number of ways, including:

  • Through our understanding of the current landscape advising on options open to clients and settling disputes with HMRC involving avoidance issues;
  • Advising on and challenging APNs / follower notices.  Pinsent Masons has been at the forefront of legal challenges made in this area;
  • Litigating cases involving tax avoidance before the tax tribunal.

Read more about follower notices and accelerated payment notices on

Read more about our Tax Investigations expertise.

Key Contacts