Follower and accelerated payments notices

On 17 July 2014, the Finance Act 2014 (FA 2014) introduced two anti-avoidance provisions available for HMRC to combat perceived tax avoidance—follower notices and accelerated payment notices (APNs) or partner payment notices (PPNs). For the key points to note about follower notices and APNs/PPNs, see: Quick guide to follower notices and APNs—checklist.

What are follower notices?

Provided four conditions are met, HMRC can give follower notices to taxpayers who have used an avoidance scheme that has been shown to fail in another person's litigation (ie an earlier final judicial ruling). A follower notice is designed to counteract the tax advantage by incentivising the recipient of the follower notice to concede to HMRC's view and to take any necessary corrective action, such as amending a return or a claim, or to drop its appeal in accordance with the earlier final judicial ruling and therefore save HMRC the time and expense of having to litigate the same issue again. Failure to take corrective action within the required time gives rise to a penalty. For more information, see Practice Note: Follower notices.

A follower

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