HMRC’s recent guidance on the new rules on follower notices and accelerated payments is not as extensive as hoped. However, the guidance helpfully confirms that: follower notices are likely to be issued only in connection with marketed schemes; the decision to issue follower notices will be made by a senior HMRC governance panel; any taxpayer representations regarding the validity of follower notices and accelerated payment notices will be considered by an independent HMRC team; and any taxpayer reliefs, allowances and losses that are unrelated to the challenged scheme will be taken into account in computing the amount under the accelerated payment notice.
