Mark Middleditch (Allen & Overy) provides this month’s update on developments affecting the City.
Accelerated payment notices (APN)
HMRC has successfully fended off another judicial review of its decision to issue an APN. Under the FA 2014 where a disclosure of tax avoidance scheme (DOTAS) disclosure has been made and the scheme is disputed by HMRC an APN can be issued requiring payment of the tax in dispute to HMRC upfront. The purpose of the APN rules is to make sure that HMRC and not the taxpayer holds onto the tax until the dispute is resolved.
In Vital Nut Co. Ltd and others v HMRC [2016] EWHC 1797 (Admin) (reported in Tax Journal 5 August 2016) HMRC argued that it could issue a valid APN whenever a DOTAS disclosure was made...
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Mark Middleditch (Allen & Overy) provides this month’s update on developments affecting the City.
Accelerated payment notices (APN)
HMRC has successfully fended off another judicial review of its decision to issue an APN. Under the FA 2014 where a disclosure of tax avoidance scheme (DOTAS) disclosure has been made and the scheme is disputed by HMRC an APN can be issued requiring payment of the tax in dispute to HMRC upfront. The purpose of the APN rules is to make sure that HMRC and not the taxpayer holds onto the tax until the dispute is resolved.
In Vital Nut Co. Ltd and others v HMRC [2016] EWHC 1797 (Admin) (reported in Tax Journal 5 August 2016) HMRC argued that it could issue a valid APN whenever a DOTAS disclosure was made...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
.jpg?sfvrsn=335a554c_0 "300 x 250 (MPU)")