The imposition of penalties on enablers of defeated tax avoidance schemes is designed to prevent and discourage designers, marketers and facilitators of abusive tax avoidance schemes and arrangements.

The introduction and expansion of this legislation is part of a broader government drive over a number of years to eliminate tax evasion and aggressive tax planning. Further initiatives in this area include the general anti-abuse rule (GAAR), issuing Promoters of tax avoidance schemes (POTAS) with Conduct notices, the imposition of criminal offences on promoters and offshore tax evaders and the introduction of a further revised version of the Professional Conduct in Relation to Taxation guidance (see General Principles of tax avoidance—Private Client—overview for further information).

At Spring Statement 2025 on 26 March 2025, the government published a consultation on a package of measures designed to close in on promoters (and other enablers) of marketed tax avoidance, with the consultation running to 18 June 2025. The four areas covered by the proposals include the introduction of  ‘Universal Stop Notices’ and ‘Promoter Action Notices’ to address