HMRC's guidance on accelerated payments and follower notices

HMRC’s recent guidance on the new rules on follower notices and accelerated payments is not as extensive as hoped. However, the guidance helpfully confirms that: follower notices are likely to be issued only in connection with marketed schemes; the decision to issue follower notices will be made by a senior HMRC governance panel; any taxpayer representations regarding the validity of follower notices and accelerated payment notices will be considered by an independent HMRC team; and any taxpayer reliefs, allowances and losses that are unrelated to the challenged scheme will be taken into account in computing the amount under the accelerated payment notice.