For the three years in question, the disclosure regime provided early warning of tax avoidance which enabled HM Revenue & Customs (HMRC) to develop strategies for handling the risks posed long before the tax returns were received. These strategies have resulted in changes to tax legislation and the challenge of the scheme users' returns through project-managed enquiries.
HMRC is progressing these enquiries which may lead to litigation in appropriate cases. Where HMRC has litigated, it has had a high level of success, winning the significant majority of cases since April 2010.
The specific information requested can be provided only at a disproportionate cost.