In his latest update on the world of tax Peter Vaines has mixed opinions on new guidance from HMRC
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The new rules for accelerated payments and follower notices are now in force so that anybody who has participated in a disclosure of tax avoidance scheme, or in due course has an arrangement which is given the thumbs down by the GAAR Advisory Panel, is likely to have to pay the disputed tax up front.
Actually, there does not need to be any tax in dispute. Indeed, it seems clear that in many cases there will be no dispute. But you still have to pay the tax until such time as HMRC decide (if they do) that it is not disputed.
The same applies to a follower notice where HMRC is of the opinion that there is a final judicial ruling in another case which if applied to your case, would deny the tax advantage. HMRC can then ask you to
