In April 2016, HMRC published a consultation on the reform and extension of the disclosure of VADR and proposed changes to the inheritance tax hallmark regulations.

With regard to VAT, there are three aims: reform of VADR so that it more closely resembles the disclosure of tax avoidance schemes (DOTAS) regime; move the primary obligation to disclose VAT avoidance schemes from users to promoters; and consider the extent to which the other requirements of DOTAS should be carried across to a revised VADRA.

The Law Society has published its comments on these proposals. It raises concerns regarding the compatibility of the proposed rules with EU law; whether the proposals are too broad; and, whether those who may be subject to the rules will be able to comply with them.

The Law Society’s response can be found here.