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Implications of follower notices and accelerated payment demands
KEY POINTS
- Accelerated payment notices are being sent out to some scheme participants.
- They require payment of the tax pending any appeal or enquiry with no power to appeal to an independent tribunal
- Follower notices are issued when HMRC believe that a final judgment in a case affects that of a taxpayer.
- If the taxpayer does not give in and adjust their tax return a penalty of 50% of the tax will apply unless the taxpayer eventually wins the case.
- Are HMRC trying to make people think they have issued follower notices when they haven’t?
The pitch for a pre-packaged tax avoidance scheme used to be quite simple. “Look ” the promoter or intermediary would say to the potential investor “what’s going to happen if you don’t invest?
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