HMRC have published the terms of what they refer to as a new ‘settlement opportunity’ specific to certain avoidance schemes which, in their opinion, are open to challenge.

Members should note that HMRC are beginning to make contact via letter with all those who they believe are eligible to participate. Without prejudice to the probity of any arrangements, more details are available from HMRC website and the What's New section of the website.

The manner of the announcement is an inappropriate conflation in the treatment of avoidance and evasion by HMRC, and hopefully will not give rise to any confusion.