HMRC has published a new compliance checks series factsheet CC/FS36a protective GAAR notices, explaining the new protective GAAR notices which were introduced by FA 2020 with effect from 22 July 2020, replacing the existing rules on provisional counteraction notices. The Factsheet outlines the general process including counteractions by HMRC and notes that, although there is no right of appeal against the protective GAAR notice itself, taxpayers can appeal against any resulting tax adjustments.
HMRC has published a new compliance checks series factsheet CC/FS36a protective GAAR notices, explaining the new protective GAAR notices which were introduced by FA 2020 with effect from 22 July 2020, replacing the existing rules on provisional counteraction notices. The Factsheet outlines the general process including counteractions by HMRC and notes that, although there is no right of appeal against the protective GAAR notice itself, taxpayers can appeal against any resulting tax adjustments.
