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Introduction

Over many years, successive Governments have introduced measures to curb what they have seen as being unacceptable tax avoidance. This is different to tax evasion, where sums or sources of income or gains are concealed or omitted from a taxpayer’s returns. Avoidance is where the taxpayer uses the way in which tax law, or a combination of tax laws, works to achieve a tax advantage, such as minimising or delaying tax bills (or maximising or accelerating a tax repayment), otherwise than where the legislation in question was introduced with the aim of delivering that tax advantage.

In addition to the inclusion of numerous specific anti-avoidance provisions designed to stop identified avoidance schemes, the UK tax code includes several wider anti-avoidance tools:

1. •

   the regime for disclosure of tax avoidance schemes (DOTAS) ― aimed at providing HMRC with early intelligence about avoidance

2. •

   the general anti-abuse rule (GAAR) ― aimed at counteracting