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Finance Bill 2026: HMRC’s expanded anti-avoidance regime—general prohibition on promoting ineffective schemes, USR and PANs, new AAINs, strengthened DOTAS/DASVOIT penalties, and publication powers over legal professionals

Published on: 10 December 2025

Published by a LexisNexis Tax expert
Legal News
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Article summary

What lies behind the measures announced at Budget 2025, and set out in Finance Bill 2026, aimed at promoters of marketed tax avoidance?

Although the government’s recent policy paper and earlier consultations use the term ‘promoters’, the scope of the changes extends to a far broader population indeed.

This marks the latest step in HMRC’s sustained drive to eliminate entirely the practice of creating a ‘tax avoidance scheme’.

What began with DOTAS (Disclosure of Tax Avoidance Schemes) in 2004 has widened markedly over the intervening twenty years.

Across that period, its reach and application have expanded significantly and persistently too.

These particular proposals first appeared in a consultation announced at the Autumn Budget 2024 and launched at the Spring Statement 2025, and those proceeding now feature in Finance Bill 2026 (also known as Finance (No 2) Bill 2024–26), published on 4 December 2025.

What are the measures? DOTAS and DASVOIT

Long-standing rules already allow HMRC to impose very significant penalties for failing to meet specific duties linked to DOTAS and the Disclosure of tax avoidance schemes for VAT and other indirect taxes (DASVOIT), including the core duty to notify full details of schemes...

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