Challenging follower and accelerated payment notices

Patrick Cannon

Taxpayers who wish to explore the possibility of resisting follower notices or accelerated payment notices received from HMRC should weigh up their options carefully. Patrick Cannon (15 Old Square) sets these out

Pursuing a substantive appeal

If a taxpayer has received a follower notice and/or an accelerated payment notice but after careful consideration and advice decides to pursue an appeal to the tax tribunal on the substantive merits of his transaction or claim the context will be one or both of the following:

he has been issued with a follower notice (FA 2014 s 204): either the taxpayer will already be under a tax enquiry into a return or a claim made by him; or he will have issued an appeal in relation to an assessment or notice but...

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Pursuing a substantive appeal

he has been issued with a follower notice (FA 2014 s 204): either the taxpayer will already be under a tax enquiry into a return or a claim made by him; or he will have issued an appeal in relation to an assessment or notice but...

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: