In Pitcher, the tribunal has considered HMRC’s entitlement to issue a penalty following non-payment of an accelerated payment notice. Gideon Sanitt (Macfarlanes) reviews the impact of that decision.
In 2014 accelerated payment notices (APNs) were introduced supposedly to target taxpayers who entered into avoidance arrangements and then frustrated HMRC enquiries in order to take advantage of the cash flow benefit of the unpaid tax.
Since 2014 HMRC has reportedly issued in the region of 70 000 accelerated payment notices and collected £3bn in tax.
This industrial scale issuing of APNs including cases where taxpayers have been forced to apply for closure notices in the face of HMRC delays suggests that they are not restricted to obstructive taxpayers.
In fact APNs have been about changing the calculus of tax avoidance and dissuading taxpayers from what HMRC regards as ‘bad’ tax behaviour as much as they...
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In Pitcher, the tribunal has considered HMRC’s entitlement to issue a penalty following non-payment of an accelerated payment notice. Gideon Sanitt (Macfarlanes) reviews the impact of that decision.
In 2014 accelerated payment notices (APNs) were introduced supposedly to target taxpayers who entered into avoidance arrangements and then frustrated HMRC enquiries in order to take advantage of the cash flow benefit of the unpaid tax.
Since 2014 HMRC has reportedly issued in the region of 70 000 accelerated payment notices and collected £3bn in tax.
This industrial scale issuing of APNs including cases where taxpayers have been forced to apply for closure notices in the face of HMRC delays suggests that they are not restricted to obstructive taxpayers.
In fact APNs have been about changing the calculus of tax avoidance and dissuading taxpayers from what HMRC regards as ‘bad’ tax behaviour as much as they...
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:
