The appellants, Property 118 Limited and Cotswold Barristers Limited, have won their case at the First Tier Tribunal (FTT) related to various property tax planning schemes which HMRC argued were in breach of the Disclosure of Tax Avoidance Schemes (DOTAS) rules as they had not advised HMRC of ‘notifiable schemes’. This led to a dispute over HMRC’s allocation of scheme reference numbers (SRNs) under section 311 of the Finance Act 2004.

In HMRC’s view, the appellants, as ‘promoters’ of the arrangements, had not complied with their obligations under the DOTAS Rules to notify the arrangements to HMRC.

The tribunal took place over 10 days in February, and the final ruling running to 143 pages was released on 31 July, going in favour of Property 188 and Cotswold Barristers.