Steven Porter and Sam Wardleworth (Pinsent Masons) provide a refresher guide to these ‘game changing’ regimes.
Accelerated payment notices (APNs) and follower notices (FNs) were introduced by FA 2014 Part 4 with effect from 17 July 2014. APNs require taxpayers in avoidance cases to pay disputed tax upfront before resolution of their dispute to encourage them to settle their dispute early. FNs put pressure on users of marketed avoidance schemes to settle or face a large penalty where HMRC has succeeded in the courts against one scheme user or even against a substantially similar scheme. They were described as a ‘game changer’ for HMRC in 2015 by David Gauke the then financial secretary to the Treasury.
The rules apply to income tax capital gains tax corporation tax apprenticeship levy inheritance tax stamp duty land tax and the annual tax on enveloped dwellings (FA 2014...
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Steven Porter and Sam Wardleworth (Pinsent Masons) provide a refresher guide to these ‘game changing’ regimes.
Accelerated payment notices (APNs) and follower notices (FNs) were introduced by FA 2014 Part 4 with effect from 17 July 2014. APNs require taxpayers in avoidance cases to pay disputed tax upfront before resolution of their dispute to encourage them to settle their dispute early. FNs put pressure on users of marketed avoidance schemes to settle or face a large penalty where HMRC has succeeded in the courts against one scheme user or even against a substantially similar scheme. They were described as a ‘game changer’ for HMRC in 2015 by David Gauke the then financial secretary to the Treasury.
The rules apply to income tax capital gains tax corporation tax apprenticeship levy inheritance tax stamp duty land tax and the annual tax on enveloped dwellings (FA 2014...
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:
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