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Legal Terms – Follower Notice
A notification from HM Revenue and Customs informing a taxpayer that, in HMRC's assessment, an appeal submitted cannot prevail as the matter in question has already been adjudicated in a referenced case within the notice. HMRC typically issues a Follower Notice and an Accelerated Payment Notice concurrently, with the latter mandating payment of the contested tax within 90 days. The purpose of this legislation (Finance Act 2014 § 204–233) is to empower HMRC to efficiently and swiftly collect taxes from all taxpayers who have participated in a tax evasion scheme deemed ineffective by a court ruling against one taxpayer. These regulations constitute an assault on tax avoidance, mandating that a promoter of tax avoidance schemes disclose to HMRC the identities of clients who have implemented the plan. Similar to the General Anti-Abuse Rule, these rules undermine the established premise that direct tax is owed solely upon the issuance of an assessment and the resolution of any appeals about that assessment. The rules confer upon HMRC authorities that were once exclusive to independent tax tribunals and the judiciary.
A notification from HM Revenue and Customs informing a taxpayer that, in HMRC's assessment, an appeal submitted cannot prevail as the matter in question has already been adjudicated in a referenced case within the notice. HMRC typically issues a Follower Notice and an Accelerated Payment Notice concurrently, with the latter mandating payment of the contested tax within 90 days. The purpose of this legislation (Finance Act 2014 § 204–233) is to empower HMRC to efficiently and swiftly collect taxes from all taxpayers who have participated in a tax evasion scheme deemed ineffective by a court ruling against one taxpayer. These regulations constitute an assault on tax avoidance, mandating that a promoter of tax avoidance schemes disclose to HMRC the identities of clients who have implemented the plan. Similar to the General Anti-Abuse Rule, these rules undermine the established premise that direct tax is owed solely upon the issuance of an assessment and the resolution of any appeals about that assessment. The rules confer upon HMRC authorities that were once exclusive to independent tax tribunals and the judiciary.
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