On 17 October 2016, UK HMRC published updated guidance on the disclosure of tax avoidance schemes (DOTAS). Under the DOTAS regime, the promoters of schemes are required to disclose to HMRC that the schemes are being made available or implemented. Disclosures must also be provided by users of avoidance schemes and by employers of employees who may be using such schemes. Various penalties apply for failing to comply with the DOTAS requirements, including a maximum penalty of up to GBP 1 million…