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Accelerating away

06 May 2014 / Phil Berwick
Issue: 4450 / Categories: Comment & Analysis , Admin , Avoidance , Budget/Finance Act , Compliance

Issues relating to follower notices and accelerated payments in cases of marketed avoidance


  • HMRC publish responses to their Tackling Marketed Tax Avoidance consultation document.
  • HMRC is dismissive of pragmatic observations by the tax profession.
  • Right of appeal against follower notices and accelerated payment notices denied.
  • HMRC’s plan of action is detailed in their response document.
  • There is a need for increased HMRC resources.
  • Further HMRC guidance to be published in May 2014.

The government recently published the draft Finance (No 2) Bill 2014. This follows fairly rapid developments over the past few months and new measures to tackle marketed tax avoidance which were announced in the Autumn Statement on 5 December 2013.

These included the introduction of a scheme of accelerated payment notices to taxpayers where they have used an arrangement which is the same or very...

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