Geoff Lloyd (EY) discusses the impact of a second Court of Appeal decision in six months that has overturned follower and accelerated payment notices.
The follower notice (FN) and accelerated payment notice (APN) regime as introduced in FA 2014 is used by HMRC to encourage taxpayers to abandon a dispute where the matter has been determined by a final ruling by the courts in another case. Taxpayers who persist with a dispute despite a validly issued FN face a potential penalty of up to 50% of the tax at stake and an APN requires the taxpayer in any event to pay the disputed tax upfront. With no right of appeal against a FN or an APN the only avenue of challenge is through judicial review.
Mr Locke an investor in an Eclipse film partnership represented by David Ewart QC instructed by EY sought judicial...
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Geoff Lloyd (EY) discusses the impact of a second Court of Appeal decision in six months that has overturned follower and accelerated payment notices.
The follower notice (FN) and accelerated payment notice (APN) regime as introduced in FA 2014 is used by HMRC to encourage taxpayers to abandon a dispute where the matter has been determined by a final ruling by the courts in another case. Taxpayers who persist with a dispute despite a validly issued FN face a potential penalty of up to 50% of the tax at stake and an APN requires the taxpayer in any event to pay the disputed tax upfront. With no right of appeal against a FN or an APN the only avenue of challenge is through judicial review.
Mr Locke an investor in an Eclipse film partnership represented by David Ewart QC instructed by EY sought judicial...
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