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ROWE


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. 
 
‘They also pay who only sit and wait…’ Michael Conlon QC and Julian Hickey (Temple Tax Chambers) examine the High Court decision in Rowe on the legality of partner payment notices.
 

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).

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