Commentary

A7.330 Introduction to sanctions for serial tax avoidance

Administration and compliance

A7.330 Introduction to sanctions for serial tax avoidance

Sanctions for serial tax avoidance

A7.330 Introduction to sanctions for serial tax avoidance

A regime of warnings and escalating sanctions applies for those who persistently and repeatedly use tax avoidance schemes which are defeated by HMRC1, and can be summarised as follows:

  1.  

    •     following the first defeat of a tax avoidance scheme, HMRC will issue a warning notice to the taxpayer, which will last five years initially

  2.  

    •     during the warning notice period, the taxpayer must report annually to HMRC regarding their activities (and particularly any tax avoidance activities) in that year

  3.  

    •     if a further tax avoidance scheme used by the taxpayer in the warning notice period is defeated by

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