DOTAS and relevant property trusts

I am sure I should know the answer to this but, is it necessary to disclose (or for the client to do so) setting up a relevant property trust which will hold one half share of a residential property, where the only exemption to be used is the nil rate band and capital gains tax holdover relief? I do not think that this comes within the confidentiality or premium fee hallmarks as it is not a scheme or new but how would HMRC view it? Is it better to disclose than not?

Amanda Woolven
The Oakley shee Partnership

At present, in relation to inheritance tax, the requirement to disclose arises only in relation to the IHT entry charge, and if the gift is within the NRB there isn’t an entry charge to avoid. No disclosure required

Tim Gibbons