Follower notices and accelerated payment notices were introduced with the stated purpose of encouraging users of avoidance schemes to settle their tax affairs once the scheme had been defeated in the courts, and to require disputed tax in avoidance cases to sit with HMRC. Initial concerns as to the discretion given to HMRC, and the perceived inadequacy of taxpayer safeguards, have resurfaced in a series of judicial reviews which have been determined in favour of HMRC. The refusal of the courts to date to interfere with HMRC’s exercise of these powers should be borne in mind when deciding whether to challenge such notices.
