Since 2010 the government has legislated for the general anti-abuse rule (GAAR) and introduced the high risk promoters rules as well as bringing in accelerated payment notices (APNs) and follower notices (FNs). All of this was designed to deter tax avoidance to reduce the cash flow advantages of delaying the payment of tax by using avoidance schemes and to bring enquiries to a close sooner. The government perceives that further measures are needed to deter ‘persistent avoiders’. HMRC is now consulting until 12 March 2015 on:
