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The Finance Act 2014 introduced significant new powers for HMRC. These powers require taxpayers that have used avoidance schemes to pay the disputed tax upfront.
Accelerated payment notices also remove the cash advantage of sitting and waiting during an avoidance dispute. Penalties of up to 15% of the disputed tax may apply to late payment.
The new legislation can affect individuals, partnerships, companies and trusts where there is an open appeal or enquiry. It also applies to past arrangements, not just arrangements entered into after its enactment on 17 July 2014. HMRC has issued a list of all 'disclosure of tax avoidance schemes' (DOTAS) scheme reference numbers, for which it will issue accelerated payment notices.
At Grant Thornton, we can help you capitalise on an opportunity to review your planning arrangements and consider early settlement. If your funds to pay the disputed tax upfront are limited, now's the time to consider requesting time-to-pay arrangements with HMRC. This will help minimise late payment penalties.
We can also help you if you're in receipt of an accelerated payment notice or expect to receive an accelerated payment notice, because HMRC listed your DOTAS scheme reference number. We can help you understand your rights and obligations, and advise you on the best course of action.
If you're facing an accelerated payment notice, it's wise to seek professional advice. At Grant Thornton, our specialist National Tax Investigations team is qualified to bring you the expert insight and support you need.
+44 (0)161 953 6406Partner contact: Grant Summers