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.
There has been a lot of comment on accelerated payment notices (APNs) since they were introduced in 2014. Their introduction has been a bumpy road with legal challenges that still rumble on and the odd misstep by HMRC. The highest profile of these was the withdrawal of several hundred APNs last week after 2 000 APNs were withdrawn late last year when HMRC accepted that the legislative requirements were not met: although the arrangements were notified to HMRC purportedly under DOTAS they were not notifiable.
HMRC’s mistake in relation to the 2 000 withdrawn APNs seems to be quite straightforward. Promoter A made a disclosure apparently...
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Home >Articles > HMRC’s misunderstanding of accelerated payment notices
HMRC’s misunderstanding of accelerated payment notices
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.
There has been a lot of comment on accelerated payment notices (APNs) since they were introduced in 2014. Their introduction has been a bumpy road with legal challenges that still rumble on and the odd misstep by HMRC. The highest profile of these was the withdrawal of several hundred APNs last week after 2 000 APNs were withdrawn late last year when HMRC accepted that the legislative requirements were not met: although the arrangements were notified to HMRC purportedly under DOTAS they were not notifiable.
HMRC’s mistake in relation to the 2 000 withdrawn APNs seems to be quite straightforward. Promoter A made a disclosure apparently...
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If you do not subscribe but are a registered user, please enter your details in the following boxes:
