UK: Accelerated payment notices issued to partners upheld

UK: Accelerated payment notices

Taxpayers invested in a film partnership sought judicial review challenging the legality of partner payment notices. The UK High Court, however, rejected the challenge to the legality of payment notices issued by HM Revenue & Customs to the investors in the film partnership. HMRC has announced that it expects to issue approximately 64,000 advance payment notices by the end of 2016.


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Although the tax position of the film partnership in which the taxpayers invested has not yet been decided by the courts, HMRC issued the partners with partner payment notices. These notices—a form of accelerated payment notice used for members in a partnership—require the partners to pay the disputed tax liabilities upfront. 

Some of the partners challenged these payment notices, requesting a judicial review in the High Court on various grounds. The High Court, however, upheld the authority of HMRC to issue the accelerate payment notices.

Read an August 2015 report prepared by the KPMG member firm in the UK: Weekly Tax Matters (7 August 2015)

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