Angela Savin (Norton Rose Fulbright) examines HMRC’s recent guidance on its new powers in this year’s Finance Act.
In a flurry of activity around royal assent HMRC published both its guidance on follower notices and accelerated payment notices (APNs) and the first list of approximately 1 200 disclosure of tax avoidance schemes (DOTAS) reference numbers in respect of which HMRC intends to issue an APN.
Although legislating through guidance is never to be encouraged the guidance is somewhat thinner than one would have hoped.
Many concerns have been expressed about the breadth of HMRC’s power to issue follower notices. Although it will not be possible to be fully confident of the practical application of the legislation...
