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Back to basics: Accelerated payment notices and follower notices

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Accelerated payment notices and follower notices were game changers when introduced in 2014, requiring disputed tax to be paid up-front and imposing substantial penalties on taxpayers who refuse to settle when HMRC has won a judicial ruling ‘relevant’ to their arrangements. There is no right of appeal, only a right to make written representations, which makes judicial review the only potential remedy. The courts have been largely unwilling to interfere with the operation of the regime. The number of notices issued has slowed significantly since their 2015/16 heyday. Taxpayers receiving one should ensure the notice is valid and must follow the correct procedure to avoid penalties.

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