| 释义 |
Follower Notice
A notice that can be issued by HM Revenue and Customs notifying a taxpayer that, in the view of HMRC, an appeal he had made cannot succeed as the issue in the appeal has been already decided in a case named in the notice. HMRC practice is to issue, simultaneously, a Follower Notice and an Accelerated Payment Notice, the latter requiring payment of the tax in dispute within 90 days. The intention of this legislation (Finance Act 2014 s 204–233) is to enable HMRC to collect tax efficiently and rapidly from all taxpayers who have engaged in a tax avoidance scheme that has been declared ineffective by a court judgment against one taxpayer. These provisions can be regarded as part of an attack on tax avoidance that includes the requirement for a promoter of tax avoidance schemes to reveal to HMRC the identity of his clients who have adopted the scheme. Like the General Anti-Abuse Rule, these provisions defeat the long-standing principle that direct tax is payable only when an assessment has been raised and any appeal against the assessment determined. The provisions give HMRC powers that were previously reserved to independent tax tribunals and the courts. |