In the First-Tier Tribunal Tax Chamber, Rory Mullan QC acted for the Respondents, both named Smartpay Limited but one incorporated in UK and the other in the Isle of Man). HMRC argued the scheme was notifiable and the Respondents were both promoters. The Tribunal consider that the UK company was a promoter notwithstanding its more limited role in the arrangements. It also concluded that the Isle of Man company was within the scope of the DOTAS provisions. For more information on this case, please view the judgment.