Geoff Lloyd and Dan White (EY) examine recent court decisions which tend to favour HMRC’s application of the FN and APN provisions.
The follower notice (FN) and accelerated payment notice (APN) provisions (FA 2014 Part 4 and 30 to 33) were introduced as part of HMRC’s strategy for tackling marketed tax avoidance. Their stated purpose was to encourage people who had used an avoidance scheme to settle their tax affairs once the scheme had been defeated in the and to require disputed tax in avoidance cases to sit with HMRC rather than the taxpayer even if an enquiry is ongoing or there is an open appeal. The measures passed into law in the face of considerable concerns from tax professional bodies as to the extent of the apparently unfettered discretion given to HMRC and the perceived inadequacy of taxpayer safeguards. Those concerns have subsequently resurfaced in a...
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Geoff Lloyd and Dan White (EY) examine recent court decisions which tend to favour HMRC’s application of the FN and APN provisions.
The follower notice (FN) and accelerated payment notice (APN) provisions (FA 2014 Part 4 and 30 to 33) were introduced as part of HMRC’s strategy for tackling marketed tax avoidance. Their stated purpose was to encourage people who had used an avoidance scheme to settle their tax affairs once the scheme had been defeated in the and to require disputed tax in avoidance cases to sit with HMRC rather than the taxpayer even if an enquiry is ongoing or there is an open appeal. The measures passed into law in the face of considerable concerns from tax professional bodies as to the extent of the apparently unfettered discretion given to HMRC and the perceived inadequacy of taxpayer safeguards. Those concerns have subsequently resurfaced in a...
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