HMRC faces repayment of potential £45m of follower notice penalties

HMRC may have to repay tens of millions in follower notice penalties issued to taxpayers, after a key decision in the Supreme Court last month cast doubt on their legitimacy

In response to a freedom of information request by law firm Fieldfisher, HMRC confirmed 1,330 follower notice penalties totalling around £45m have been issued by HMRC since the follower notice regime was introduced in 2014.

The Supreme Court decision (R (Haworth) v Revenue and Customs Comrs [2021] UKSC 25), handed down on 2 July 2021, called into question the authority of all follower notices issued by HMRC to tackle perceived tax avoidance.

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