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...

SDLT DOTAS: disclosure triggers, excluded arrangements (steps A–F), promoter and taxpayer duties, legal professional privilege, and Finance Bill 2026 promoter‑targeted reforms (England and Northern Ireland)

Published by a LexisNexis Tax expert

Practice notes

FORTHCOMING CHANGES :

At Budget 2025, the government stated it will legislate via Finance Bill 2026 (also known as Finance (No 2) Bill 2024–26) to introduce measures targeting promoters or enablers of marketed tax avoidance. The provisions are set out in Part 6 of the Bill (as introduced on 4 December 2025) and cover:

updates to the DOTAS and DASVOIT civil penalty regime so that HMRC can issue DOTAS penalties directly, rather than seeking tribunal approval;
a general prohibition on promoting marketed arrangements that have no realistic prospect of success, and a prohibition on promoting arrangements specified in universal stop regulations (USRs). A breach of either prohibition would attract a range of sanctions, including publication, financial penalties and criminal prosecution;
promoter action notices (PAN). A PAN would require businesses to cease providing goods or services to promoters of tax avoidance where those goods or services are used in the promotion of avoidance and the promoter is in breach of a USR or stop notice. PANs will primarily be issued to financial institutions, insurance companies, and social media companies...

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Web page updated on 21/05/2026

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