HM Revenue and Customs (HMRC) has issued consultation documents which include proposals for taxpayers to make accelerated payment of tax that is in dispute or subject to enquiry and for identifying “promoters” of tax avoidance schemes. The consultations are intended to make further progress in dealing with artificial tax avoidance and ensuring that artificial tax schemes do not benefit the promoters or those who use them.
The first consultation document (Tackling marketed tax avoidance) ―includes draft legislative language which would require taxpayers to settle disputed tax on receipt of a “failure notice”. The aim of the proposal is to prevent taxpayers from using delaying tactics with respect to settlement of open cases.
The second consultation document (Raising the stakes on tax avoidance) includes draft legislation which would establish how “high-risk promoters” would be identified and details the consequences for taxpayers who implement a high-risk promoter’s arrangement.
The new measures are to take effect from “Royal Assent” of Finance Bill 2014.