The vindictive legislation termed S.58, passed in the Finance Bill 2008, retrospectively changed the tax law on the use of a DTA and backdated it to 1987 (21 years).
The legislation was passed through the House of Commons by outright and blatant lies, despite that same House standing over the loopholes in 1987.
No one was given a chance to fight their battle in court under the tax law as it stood at the time. The current Government have continued to peddle false, inaccurate and misleading information on this subject.
The people who joined such schemes were contractors simply seeking some certainty in their lives when faced with the total uncertainty of IR35.
Someone has already committed suicide because of this, several others have already gone bankrupt.
Sadly, it is because of S.58 that the Government thinks they can take it one stage further with retrospection, believing their spin on tax avoidance can allow them to ride roughshod over democracy.
There have been 11 cases of retro tax legislation post-war but only one so far (S.58) deliberately targeted individual taxpayers.
DOTAS looks like being the second , although it is not law yet
More information on S.58 can be found at http://notoretrotax.org.uk/