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And then there's this, which completely misses the point that the 'in-house' exemption from DOTAS doesn't mean that a scheme doesn't have to be notified, but that it has to be notified by the user and not the promoter: https://www.property118.com/tax-avoidance-dotas-and-the-substantial-incorporation-structure-sis/ Yes folks, it appears they just exposed all their clients to a DOTAS penalty. Top work lads, absolutely sterling job.