Jurisdiction(s):
United Kingdom

Related legal acts

Key definition

Disclosure definition

What does Disclosure mean? Disclosure describes the process in litigation by which a party identifies, lists and, where not protected by privilege, allows inspection of documents within its control that are relevant to the issues in dispute, including confirming that a document exists or has existed. It covers paper and electronic material (ESI), and carries a continuing duty to preserve and disclose. In England and Wales, disclosure is governed by the Civil Procedure Rules: standard disclosure and inspection under Part 31, and in the Business and Property Courts, initial and extended disclosure under Practice Direction 57AD. Parties must conduct a reasonable and proportionate search, list...

UK DOTAS procedure: disclosure obligations, SRNs, employer and client lists, HMRC information powers, publication and penalties; includes forthcoming Finance Bill 2026 promoter measures

Published by a LexisNexis Tax expert

Practice notes

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FORTHCOMING CHANGES :

At Budget 2025, the government stated it will legislate through Finance Bill 2026 (the Finance (No 2) Bill 2024–26) to bring in measures aimed at promoters or enablers of marketed tax avoidance. These sit in Part 6 of the Bill, as introduced on 4 December 2025, and include:

amendments to the DOTAS and DASVOIT civil penalty regime, enabling HMRC to issue DOTAS penalties directly rather than seeking tribunal approval
a general ban on promoting marketed arrangements with no realistic prospect of success, and a ban on promoting arrangements named in universal stop regulations (USRs). Breach of either ban could lead to publication, financial penalties, and criminal prosecution
promoter action notices (PANs). A PAN would require businesses to stop supplying goods or services to promoters of tax avoidance where those goods or services are used to promote avoidance and the promoter is in breach of a USR or stop notice. PANs will chiefly be issued to financial institutions, insurance companies, and social media companies...

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Web page updated on 22/05/2026

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