Updated guidance has now been published in relation to the client lists rules which were introduced to the DOTAS legislation from 1 January this year.

From 1 January 2011 promoters are required to provide quarterly lists of clients to whom they are obliged to issue a scheme reference number (SRN). The lists apply to schemes disclosed at any time. If a scheme was disclosed before 1 January 2011 a promoter will have to provide a client list in respect of any clients to whom he becomes required to issue a SRN on or after that date.

It will not be necessary to provide a client list in respect of any clients to whom a promoter was required to issue a SRN before 1 January 2011 (even if the SRN is actually issued on or after that date). HMRC intends to use the information from client lists to assess and?monitor the level of risk posed by disclosed arrangements. As is customary, failure to provide client lists in accordance with the rules described in the updated guidance may result in a penalty

The guidance can be accessed at http://www.hmrc.gov.uk/avoidance/client-lists.pdf and at http://www.hmrc.gov.uk/avoidance/dotas-update-nov10.htm