Proposals to amend follower notice penalties

On 16 December 2020 HMRC issued a consultation document on follower notices and associated penalties (tinyurl.com/hmrcfnpabc). This is in advance of numerous proposed legislative changes to counter tax avoidance and comes after statements made by HMRC in 2020 signalling a renewed effort to take serious action against those who continue to develop and promote aggressive tax planning.

Many of us as members of recognised professional bodies with significant taxation responsibilities who go about our business in compliance with our Professional Conduct in Relation to Taxation (PCRT) obligations would say ‘it’s about time’. We tend to ask why HMRC has not acted sooner instead of focusing on the unsuspecting and often innocent taxpayer who was presented with what sounded like ‘a good idea’.

Some might consider HMRC’s existing investigation and remediation powers to be more than adequate. However  as shown in this latest consultation...