Taxpayers who have participated in Disclosed Avoidance Planning, may not have been fully aware of the HMRC enquiry process.
These HMRC enquiries take a significant amount of time to to resolve and can be particularly stressful.
We are able to provide you with the support and assistance you need to help bring that enquiry to an end.
Follower Notices and Accelerated Payments
New legislation was introduced in July 2014 “Follower Notices and Accelerated Payments”.
This gives HMRC the power to disregard tax planning disclosed to them under the Disclosure of Tax Avoidance Schemes (”DOTAS”) regime.
These rules allow HMRC to raise an assessment for all tax in dispute until the case has been settled.
In addition, HMRC have the power for non-DOTAS schemes which are under enquiry to issue a “Follower Notice”. This allows them to assess disputed tax where they have successfully challenged similar tax schemes.
These new rules represent a dramatic change in UK tax law and will result in many taxpayers having an unexpected financial burden.
If you have received a Accelerated Payment Notice (“APN”), Partner Payment Notice (“PPN”) or Follower Notice we can check HMRC’s calculations and provide advice and support as required.
Please contact us if you would like assistance with any of these matters.