APNS

Jeanette Zaman and Zoe Andrews (Slaughter and May) review recent developments affecting the City.

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.

Patrick Cannon

Taxpayers should question their legal advisers carefully about bringing future challenges to the accelerated payment notices regime if they are not to throw good money after bad. Patrick Cannon (15 Old Square) reviews the four reported judicial review challenges to APNs of note.

Chris Davidson

Chris Davidson (KPMG) believes that HMRC has misinterpreted the 2004 DOTAS rules by issuing APNs on the basis that they are substantially the same as a previous transaction that was notifiable under DOTAS.

Cathya Djanogly

Claim for judicial review of an advance payment notice rejected

Peter Vaines

Peter Vaines (Field Court Tax Chambers) suggests it is time for Parliament to step in to counter unintended consequences of APNs.

Thomas Dalby

Thomas Dalby (Gabelle) looks at HMRC’s next move following the closure of the EBT settlement opportunity.

Mark Middleditch

Mark Middleditch (Allen & Overy) reviews the latest tax developments that matter affecting the City.

Santhie Goundar

The High Court has rejected a judicial review application challenging the legality of accelerated payment notices, as well as their compatibility with human rights (Nigel Rowe and others v HMRC [2015] EWHC 2293).