Machinations of follower notices and accelerated payment notices

As part of the government’s clampdown on aggressive tax avoidance schemes, HMRC was given powers to issue follower notices and accelerated payment notices (APNs). Meg Wilson CTA, specialist tax writer at Croner-i, examines their effectiveness and the grounds for cases won by taxpayers

Follower notices and accelerated payment notices (APNs) were introduced by Finance Act 2014 (FA 2014), Pt 4, as a tax avoidance deterrent.

This article recaps the rules for follower notices and APNs, lessons learnt from some of the key tax cases and considers the effectiveness of the regime.

The basics of follower notices and APNs

HMRC can issue a follower notice to a taxpayer who has used an avoidance scheme which has been shown in another taxpayer’s litigation to be ineffective. The recipient is required to amend their return or settle their dispute, and tell HMRC that they have done so.

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The basics of follower notices and APNs

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