DOTAS and DASVOIT: UK sources, HMRC guidance across direct and indirect taxes, and forthcoming Finance Bill 2026 measures on promoters and enablers — quick reference table

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FORTHCOMING CHANGES :

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

updates to the DOTAS and DASVOIT civil penalty regime, enabling HMRC to issue DOTAS penalties directly rather than seeking tribunal approval
a general prohibition on promoting marketed arrangements with no realistic prospect of success, and a prohibition on promoting arrangements specified in universal stop regulations (USRs). Breach of either prohibition could result in publication, financial penalties and criminal prosecution
promoter action notices (PAN). A PAN would require businesses to stop 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 20/05/2026

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