FOLLOWER-NOTICE

Taxpayers should question their legal advisers carefully about bringing future challenges to the accelerated payment notices regime if they are not to throw good money after bad. Patrick Cannon (15 Old Square) reviews the four reported judicial review challenges to APNs of note.

Chris Davidson

Chris Davidson (KPMG) believes that HMRC has misinterpreted the 2004 DOTAS rules by issuing APNs on the basis that they are substantially the same as a previous transaction that was notifiable under DOTAS.

Thomas Dalby

Thomas Dalby (Gabelle) looks at HMRC’s next move following the closure of the EBT settlement opportunity.

Michael Conlon KC

Julian Hickey

‘They also pay who only sit and wait…’ Michael Conlon QC and Julian Hickey (Temple Tax Chambers) examine the High Court decision in Rowe on the legality of partner payment notices.

Steve Bousher

Steve Bousher (Joseph Hage Aaronson) reviews recent decisions on accelerated payment notices as a new counter avoidance power used by HMRC.

Many contractors are being unfairly treated by the APN regime, writes Graham Webber.

Chris Davidson

Despite a general perception to the contrary, it is possible to appeal a follower notice penalty, writes Chris Davidson (KPMG)

Patrick Cannon

Patrick Cannon comments on the impact of a recent decision of the European Court of Human Rights.

Angela Savin

Angela Savin (Norton Rose Fulbright) examines HMRC’s recent guidance on its new powers in this year’s Finance Act.

Chris Davidson

Chris Davidson reviews the anti-avoidance measures in the current Finance Act and surveys the horizon for the next step in HMRC’s anti-avoidance journey.

Go to page of 3