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HMRC readies to issue follower notices and accelerated payments

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HMRC has published a tax information and impact note on the new rules which will allow it to issue conduct notices to promoters of tax avoidance schemes. The note stresses that these rules have effect since Royal Assent of the Finance Bill (i.e. 17 July 2014). Additionally, HMRC has published extensive guidance on the measures on follower notices and accelerated payments contained in the Finance Act 2014.

Follower notices will be issued to taxpayers involved in disputes with HMRC in circumstances where a court has already held that the relevant arrangement does not produce the effect intended by the taxpayer. Recipients of follower notices will have to either settle or incur the risk of a penalty.

The guidance also covers the issue of accelerated payment notices (APNs). HMRC has already published a list of over 1,200 avoidance schemes reference numbers whose users may be issued with an APN.

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