The guidance states that anyone who has been involved in a tax avoidance scheme, could receive a follower notice, accelerated payment notice (APN), or both from HMRC. It sets out the steps to follow if this happens, and warns that failure to follow them could result in having to pay a penalty.

A follower notice, which is sent after a tax avoidance scheme has been successfully challenged, asks individuals to settle their tax affairs with HMRC or potentially face a penalty.

Individuals may receive an APN if there is an enquiry, dispute or appeal in progress that relates to their r tax affairs and they have either been given a follower notice; used a disclosure of tax avoidance schemes (DOTAS) notifiable arrangement; or received a general anti-abuse rule (GAAR) counteraction notice.

The guidance states that anyone who receives an APN must pay the amount of disputed tax. HMRC says it will hold this money until the enquiry into their affairs is complete, or their appeal is resolved. The money will be returned if HMRC finds the individual does not owe it.

Failure to pay the disputed tax amount by the date on the notice, may mean having to pay a penalty.

Anyone who is a member of a partnership will receive a partner payment notice (PPN) instead of an APN. HMRC says this usually works the same as an APN, but the individual PPN will explain exactly what the individual needs to do.

Notices will tell the recipient why a notice has been sent, what they need to do next, what to do if they disagree, any relevant deadlines, and any penalties if they do not take action.

Anyone who fails to comply will receive a notice of penalty assessment telling them how much they have to pay, and by when. It also explains how the penalty is worked out.

Individuals can appeal against any penalties they receive from HMRC relating to follower notices, APNs or PPNs. However, they cannot formally appeal against a notice.

Guidance Follower notices and accelerated payments is here.