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HMRC follower notices

HMRC follower notices HMRC NOTICES

Specialist anti-avoidance legislation gives HMRC significant powers to demand upfront payment of disputed tax from taxpayers using avoidance schemes. This means that taxpayers that have used a tax avoidance scheme may have to make a payment of the amount that relates to their use of the scheme, before the final amount has been agreed or determined. This is known as an accelerated payment, or in the case of members of a partnership, it is known as an accelerated partner payment.

An accelerated payment notice (APN) may only be issued under certain circumstances such as:

  • when the taxpayer has been issued with a follower notice,
  • the taxpayer is using certain arrangements disclosable under the disclosure of tax avoidance scheme (DOTAS) rules, or
  • the recipient is subject to a counteraction notice under the General Anti-Abuse Rule.


HMRC has recently published an updated version of their factsheets on follower notices and accelerated payments (CC/FS25a) and the related notice on partnership follower notices and accelerated partner payments (CC/FS25b).

A follower notice is issued to taxpayers that have used the same tax avoidance strategy as that used by a representative case or a different scheme where a principle in that scheme is sufficiently similar to the scheme used in a representative case. The factsheets explains in more detail the circumstances under which HMRC may issue a follower notice or partnership follower notice.

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