Jeanette Zaman and Zoe Andrews (Slaughter and May) review recent developments affecting the City.
Root2tax: DOTAS
HMRC has been granted an order by the FTT (Judge Colin Bishopp) that arrangements are notifiable under FA 2004 s 314A. This means that HMRC can now issue accelerated payment notices (APNs) to the many taxpayers involved. HMRC v Root2tax [2017] UKFTT 696 appears to be the first case to apply s 314A (order to disclose) since that provision took effect in July 2007. In 2009 the special commissioners in HMRC v Mercury Tax Group [2009] STC 743 refused an application by HMRC for a penalty to be imposed for non-notification because under the rules as they applied at the relevant time in 2005 the Mercury scheme was not notifiable. The rules have undergone significant change since then.
Obtaining the order in this case is an important win for HMRC....
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Jeanette Zaman and Zoe Andrews (Slaughter and May) review recent developments affecting the City.
Root2tax: DOTAS
HMRC has been granted an order by the FTT (Judge Colin Bishopp) that arrangements are notifiable under FA 2004 s 314A. This means that HMRC can now issue accelerated payment notices (APNs) to the many taxpayers involved. HMRC v Root2tax [2017] UKFTT 696 appears to be the first case to apply s 314A (order to disclose) since that provision took effect in July 2007. In 2009 the special commissioners in HMRC v Mercury Tax Group [2009] STC 743 refused an application by HMRC for a penalty to be imposed for non-notification because under the rules as they applied at the relevant time in 2005 the Mercury scheme was not notifiable. The rules have undergone significant change since then.
Obtaining the order in this case is an important win for HMRC....
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:
