Accelerated payment notices are widely regarded as a ‘game changer’ for HMRC in its battle against tax avoidance. The idea is to remove the cashflow benefit for avoiders, by requiring them to pay the disputed tax upfront where the arrangements are notified under the DOTAS disclosure rules; subject to follower notices; or where a GAAR counteraction notice has been issued.
HMRC is now rolling out APNs, affecting many thousands of taxpayers. But there are concerns about fairness and taxpayers have mounted judivial review challenges in response.
So what is the state of play?
These must-read articles, published by Tax Journal, examine the APN landscape.
Accelerated payment notices are widely regarded as a ‘game changer’ for HMRC in its battle against tax avoidance. The idea is to remove the cashflow benefit for avoiders, by requiring them to pay the disputed tax upfront where the arrangements are notified under the DOTAS disclosure rules; subject to follower notices; or where a GAAR counteraction notice has been issued.
HMRC is now rolling out APNs, affecting many thousands of taxpayers. But there are concerns about fairness and taxpayers have mounted judivial review challenges in response.
So what is the state of play?
These must-read articles, published by Tax Journal, examine the APN landscape.
