Chris Davidson takes a look at HMRC’s recent use of APNs and the interaction with the 2004 DOTAS rules.
There has been a lot of comment on accelerated payment notices (APNs) since they were introduced in 2014. Their introduction has been a bumpy road, with legal challenges that still rumble on and the odd misstep by HMRC. The highest profile of these was the withdrawal of several hundred APNs last month after 2,000 APNs were withdrawn late last year, when HMRC accepted that the legislative requirements were not met: although the arrangements were notified to HMRC purportedly under DOTAS, they were not notifiable.
In a recent article for Tax Journal*, Chris Davidson at KPMG in the UK examines the interaction of the DOTAS rules with the APN regime, and the inconsistent basis under which HMRC have been issuing APNs.
* First published in Tax Journal on 3 June 2016. Reproduced with permission.
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