The First-tier Tribunal sided with HMRC in holding that certain arrangements were notifiable under the rules for disclosing tax avoidance schemes (FA 2004, s. 314A) – HMRC v Dark Blue Umbrella Ltd [2022] UKFTT 453 (TC):
“On the basis of all the material in the bundle, including the emails sent to the individual users, I agree with the Applicants that the Respondent made the notifiable proposal available for implementation and/or was responsible for the organisation or management of the arrangements. I am satisfied the Respondent is a promotor of the arrangements.”