The Disclosure regime is being broadened with effect from 1 August 2006, and HMRC have published notes on how the new wider schemes are to operate.

As pointed out in the HMRC document, the three main changes are:

• For income tax, corporation tax and capital gains tax purposes, the range of disclosable tax arrangements is no longer limited to employment or financial products. Under the revised rules, they potentially include any tax arrangement relating to any aspect of those taxes.
• For income tax, corporation tax and capital gains tax purposes, the range of disclosable tax arrangements is no longer limited by a series of filters. Instead a tax arrangement becomes disclosable if any one of a series of ‘hallmarks’ applies.
• Disclosure of newly implemented ‘in-house’ tax arrangements relating to income tax, corporation tax and capital gains is now due within 30 days of implementation, rather than by the filing date for the return period in which the first transaction of the tax arrangement was implemented

These changes have largely been implemented by the Tax Avoidance Schemes (Prescribed Descriptions of Arrangements) Regulations 2006 (SI 2006/1543).