The recent Budget announcement that the government has accepted the recommendations of the Aaronson Report on the introduction of a General Anti-Abuse Rule (GAAR) to the UK statute book comes as little surprise. That said, it raises the question of whether the GAAR and the Disclosure of Tax Avoidance Schemes (DOTAS) regime will make comfortable bedfellows or ought to be mutually exclusive. For the foreseeable future, both the GAAR and DOTAS need to co-exist because they approach tax avoidance from different policy perspectives and are a response to a tax avoidance 'industry' that is a uniquely UK phenomenon.
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