Follower Notices And Accelerated Payments

The UK Finance Act 2014, enacted in July 2014, contains new legislation to deal with cases of purported tax avoidance, which marks a radical departure from previous policy in this area.

Until Finance Act 2014, it was generally the case that where a taxpayer contested a direct tax assessment made by a tax authority, the appeal would suspend the need for paying the disputed liability (although interest would continue to run should the taxpayer prove to be unsuccessful). As part of its strategy to combat what it perceives to be unacceptable tax avoidance, the UK government has introduced legislation that reverses this principle in certain cases.

Under the new legislation, the UK tax authorities may issue so-called accelerated payment notices provided certain conditions are satisfied. In particular, notices may be issued where the arrangements giving rise to the tax dispute were earlier disclosed to HMRC under the disclosure of tax avoidance regulations ("DOTAS").