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Q&A on accelerated payment notices

What are the accelerated payment rules?

They are rules within the Finance Act 2014 (which became law on receiving royal assent on 17 July 2014) which apply to any taxpayer who has an open enquiry or appeal in relation to tax planning that was:

  • notifiable to HMRC under the DOTAS rules no matter how long ago; and/or
  • where HMRC has won a case against another taxpayer relating to similar arrangements and has issued a ‘follower notice’.

They will also apply in the future where a general anti-abuse rule (GAAR) counteraction notice is given in a case where the stated opinion of at least two members of the sub-panel of the GAAR advisory panel is that the tax arrangements in question are not a ‘reasonable course of action’.

The rules enable HMRC to issue an accelerated payment notice (APN) to the...

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