609. Follower notices.

The follower notice rules impose penalties where, in HMRC's view, a person involved in a tax avoidance dispute has not taken account of relevant previous judicial rulings1. HMRC may give a follower notice to a person if certain conditions are met in relation to a tax inquiry in progress where, in HMRC's view, there is a relevant judicial ruling2. The person can disagree with a follower notice by making representations to HMRC