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Accelerated payment notice decision

26 September 2017 / Andrew Hubbard
Issue: 4617 / Categories: Comment & Analysis

Changing landscape


  • Will HMRC’s win in ROOT2TAX give fresh impetus to forcing disclosure of tax avoidance arrangements?
  • Withdrawal of money from a company without a tax charge.
  • Disclosure requirements under FA 2004 s 306.
  • Did the tribunal ask the correct question?

Readers will be all too aware of the way in which accelerated payment notices (APNs) have changed the landscape. The fact that taxpayers must pay tax in advance of an appeal has led to many of them settling. There is a huge psychological difference between litigating in the hope that no tax will be payable and litigating in the hope that it will be possible to recover the tax that has already been paid.

The main trigger for the issue of an APN is the disclosure of tax avoidance schemes (DOTAS) legislation. FA 2014 ...

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