Guidance

Tax avoidance schemes — follower notices and accelerated payments

Updated 29 September 2022

We’ve given you this factsheet because you’ve used a tax avoidance scheme, and we’ll soon write to tell you about:

• taking corrective action to avoid a penalty — this is explained below in the section ‘About followers, follower notices and accelerated payments’
• making a payment of the amount that relates to your use of the scheme

If you’re a member of a partnership, we’ve given you this factsheet because the tax avoidance scheme used by the partnership is for Stamp Duty Land Tax or Annual Tax on Enveloped Dwellings. You can find more information about this on page 6 of this factsheet. If the partnership has used a tax avoidance scheme for another tax or for National Insurance contributions (NICs), then you may also need to read factsheet CC/FS25b, ‘Tax avoidance schemes — partnership follower notices and accelerated partner payments’. Go to www.gov.uk and search for ‘CC/FS25b’.

Where this factsheet refers to tax, this includes Class 4 (NICs) that are collected through Self Assessment. For the tax year 6 April 2015 to 5 April 2016 and later years, it also includes most Class 2 NICs that are collected through Self Assessment.

This factsheet is one of a series. For the full list of factsheets in the series, go to www.gov.uk and search for ‘Compliance checks factsheets’.

If you need help

If you have any health or personal circumstances that may make it difficult for you to deal with us, please tell the officer who has contacted you. We’ll help you in whatever way we can. For more information about this, go to www.gov.uk and search for ‘get help from HMRC if you need extra support’.

You can also ask someone else to deal with us on your behalf, for example, a professional adviser, friend or relative. We may however still need to talk or write to you directly about some things. If we need to write to you, we’ll send a copy to the person you’ve asked us to deal with. If we need to talk to you, they can be with you when we do, if you prefer.

About tax avoidance and avoidance schemes

Tax avoidance involves bending the rules of the tax system to gain a tax advantage that Parliament never intended. It often involves contrived, artificial transactions that serve little or no purpose other than to produce this advantage. It involves operating within the letter, but not the spirit, of the law. Most tax avoidance schemes simply do not work. Those who engage in them can find they pay more than the tax they attempted to save when HM Revenue and Customs has successfully challenged them.

The term ‘tax avoidance’ includes ‘NICs avoidance’.

About followers, follower notices and accelerated payments

Tax legislation that affects those who have used a tax avoidance scheme was introduced on 17 July 2014. The scope of that legislation was extended to cover NICs with effect from 12 April 2015. The legislation aims to:

• improve the rate at which disputes about avoidance schemes are settled where a principle on which the scheme relies has been shown in another person’s litigation to be ineffective
• remove the cash flow advantage from users of avoidance schemes by requiring an upfront payment of the disputed tax and/or NICs, so that it’s held by the Exchequer during the dispute

Followers

When we have many very similar avoidance cases, we often investigate representative cases, taking them to litigation if necessary. If the court or tribunal finds the scheme does not achieve the tax or NICs advantage in those cases, the disputes in those cases are settled. We can then recover the tax and/or NICs due.

Followers are people who’ve used:

• the same scheme that was used in a representative case
• a different scheme but where a principle in that scheme is sufficiently similar to the scheme used in a representative case

Before the legislation was introduced on 17 July 2014, there was little incentive for followers to accept that the court or tribunal’s findings in a representative case meant that their own use of the avoidance scheme did not achieve the tax or NICs advantage.

Follower notices

If a court or tribunal has made a final ruling that an avoidance scheme does not achieve the tax or NICs advantage, the legislation allows us to give follower notices to the followers.

A follower notice tells the follower that they’ll be liable to pay a penalty if they do not settle their dispute with us. The amount of the penalty for not taking corrective action on time is equal to 50% of the tax or NICs in dispute (this is called the ‘denied advantage’ in the follower notice). You can find more information about this type of penalty in the section ‘Penalties for not taking corrective action’ on page 3 of this factsheet.

The legislation for follower notices does not affect your rights of appeal to the tribunals and courts in relation to your tax or NICs liability. You can find more information about this in the section ‘What to do if you disagree with the follower notice’ on page 3 of this factsheet.

Accelerated payments

Those who’ve used an avoidance scheme may be required to make an accelerated payment. The payment will be the amount that relates to their use of that scheme before the final amount has been agreed, or determined by a tribunal or court.

If we require an accelerated payment, we’ll send an accelerated payment notice to the user of a scheme. If the user of the scheme is a follower, we may also send a follower notice.

In some circumstances we charge penalties or surcharges for not paying the accelerated payment on time. You can find more information about these on pages 7 to 8 of this factsheet.

When we may send a follower notice

If a court or tribunal has made a final ruling that a tax avoidance scheme does not achieve the tax advantage, we may send a follower notice to the followers if certain conditions are met. Those conditions are that:

• Condition A — there’s a current compliance check (referred to in the legislation as a tax enquiry) into their return or claim, or there’s an open appeal
• Condition B — their return, claim or appeal is made on the basis that there’s a particular tax advantage resulting from their chosen arrangements
• Condition C — we believe that the final judicial ruling is relevant to their chosen arrangements (because they’ve used the same, or a similar scheme)
• Condition D — we have not previously sent them a follower notice for the same scheme, the same tax advantage, the same tax period, and the same final judicial ruling — unless we’d previously sent one and then withdrawn it

If a court or tribunal made the final ruling before the legislation was introduced on 17 July 2014, we can send a follower notice at any time up to and including 16 July 2016, or 12 months after the return or claim is received, or the appeal is made, whichever is later.

If a court or tribunal made the final ruling after the legislation was introduced, we can send a follower notice up to 12 months after the later of the date on which:

• the court or tribunal made the final ruling
• we received the return or claim, or the appeal was made

Telling you that you’re subject to the follower notice rules

If you’re subject to the follower notice rules, we’ll send you a follower notice, which will tell you how to take corrective action and when. It’ll also tell you what to do if you disagree with it.

Taking corrective action

The follower notice will tell you about taking the necessary corrective action to remove the tax advantage from your use of the avoidance scheme (the follower notice uses the terms ‘counteract’ or ‘relinquish’). This will mean taking whichever of the following actions is relevant:

• amending your return or claim
• settling your appeal
• entering into a written agreement

If you make representations objecting to the follower notice, the date by which you need to take the corrective action may change. You can find more information about making representations in the next section of this factsheet.

What to do if you disagree with the follower notice

There’s no right of appeal against a follower notice. However, you can make representations to us if you believe that one or more of the following applies:

• Condition A, B or D has not been met
• the final court or tribunal ruling given in the notice is not relevant to the tax avoidance scheme that you used
• you received the notice after the deadline for us sending it to you

You can find details of these conditions and deadlines in the section ‘When we may send a follower notice’ on page 2 of this factsheet.

Your representations must be in writing, and you must make sure that you send your letter no later than 90 calendar days from the date you receive the follower notice. We’ll then consider what you say and let you know our findings. When you write to us, please:

• give us as much information as possible about your representations
• send copies of any documentary evidence that supports your representations

You cannot make representations once the 90 calendar days has passed. This means that, once we’ve told you what our findings are, you’ll not be able to make any additional representations if the 90 calendar days has already passed. So please make sure you give us all relevant information when you make your representations.

If you make representations before the date given in the notice, and we do not withdraw the notice, the deadline for taking corrective action may be extended. The deadline will be the later of:

• the date shown in the follower notice
• 30 days after the date on which you receive our decision about the representations you made

If the deadline for taking corrective action is extended, any penalty for not taking that action will apply from the extended deadline date.

The legislation for follower notices does not affect your rights of appeal to the tribunals and courts in relation to your tax liability. If you take such action and are successful — meaning that you achieve the tax advantage result that was the basis on which your return, claim or appeal was made — we’ll cancel any penalty that we’ve charged you for not taking corrective action on time.

Penalties for not taking corrective action

If you decide not to take corrective action on time, you’ll be liable to pay a penalty — unless we or the tribunal agree that it was reasonable in the circumstances for you not to have taken corrective action (read the section on page 4 ‘Appealing against the penalty if you disagree’).

The penalty for not taking corrective action will be equal to 50% of the tax advantage that was the basis on which your return, claim or appeal was made.

If we charge you a penalty, we’ll send you a notice of penalty assessment telling you how we’ve worked out the amount of the penalty.

There’s more information about penalties in our factsheet CCFS30a, ‘Tax avoidance schemes — penalties for follower notices’. Go to www.gov.uk and search for ‘CC/FS30a’.

Reducing the penalty if you co-operate with us

We can reduce the penalty percentage rate if you’ve co-operated with us before we send a notice of penalty assessment.

You’ve co-operated with us if you’ve done one or more of the following:

• provided us with reasonable help in working out the amount of the tax advantage
• counteracted the denied advantage but after you have become liable to a penalty (or relinquished the denied advantage if your follower notice relates to an appeal)
• given us information that allows us to take corrective action
• given us information that allows us to enter into an agreement with you to counteract the denied advantage
• given us access to tax records so we can make sure the denied advantage is fully counteracted

We cannot reduce the penalty percentage rate to less than 10%.

Appealing against the penalty if you disagree

If we charge you a penalty for not taking corrective action, you’ll be able to appeal against it if you disagree.

You can appeal against the amount of the penalty. You can also appeal if you believe that one or more of the following applies:

• Condition A, B or D has not been met in relation to the follower notice
• the final court or tribunal ruling given in the follower notice is not relevant to the tax avoidance scheme that you used
• you received the follower notice after the deadline for us sending it to you (the deadline is shown in the follower notice)

If your tax liability is settled on the basis that you:

• achieve the tax advantage, then we’ll cancel the penalty
• do not achieve the tax advantage, then you’ll have to pay the penalty unless you’ve successfully appealed against it

You can find more information about appeals in factsheet HMRC1, ‘HM Revenue and Customs decisions — what to do if you disagree’. Go to www.gov.uk and search for ‘HMRC1’.

The Human Rights Act and follower notice penalties

Article 6 of the European Convention on Human Rights gives you certain rights when we’re considering charging penalties.

We welcome your co-operation in taking corrective action, and in providing information about the tax advantage. If we charge you a penalty for not taking corrective action, the amount of the penalty will depend on the degree to which you co-operate with us. This is explained earlier in this factsheet.

We’ll also welcome any help you give us when establishing the amount of any penalty that we charge you for not taking corrective action on time. When we’re considering penalties you have the right not to answer our questions. The degree to which you help us is entirely your choice. In making a decision about how much you’re going to help, you have the right to consult an adviser. If you do not already have an adviser, you may want to consider consulting one.

You have the right to have the matter of penalties dealt with without unreasonable delay. If we charge you a penalty, we’ll tell you how much penalty is due when we’ve established the full extent of the co-operation that you’ve given, and the amount of the tax advantage. If you disagree with the penalty you can appeal.

You can apply for publicly funded legal assistance or Legal Aid. In some circumstances, funding may be available to help you bring certain appeals before the tribunal. If we charge you a penalty and you intend to appeal against the amount of the penalty, you may want to check whether your case qualifies for legal assistance and the type of help that may be available. We’re not involved in decisions about whether your case will qualify for legal assistance. The way you can check what help is available and the qualifying conditions depend on where you live in the UK. You can find more information from Citizens Advice or you can apply for funded legal assistance or Legal Aid through a solicitor anywhere in the UK.

If there’s anything you do not understand about these rights or what they mean for you, please tell the officer who gave you this factsheet.

When we may send an accelerated payment notice

We may send an accelerated payment notice to a person who’s used an avoidance scheme if certain conditions are met. Those conditions are set out at section 219 of the Finance Act 2014 and Schedule 2 to the National Insurance Contributions Act 2015. Those conditions are that:

• Condition A — there’s a current compliance check into their return or claim, or there’s an open appeal
• Condition B — the return or claim, or the appeal is made on the basis that there’s a tax advantage from the avoidance scheme used
• Condition C — one or more of the following applies
  • we’ve given the person a follower notice
  • the person has used arrangements that are disclosable under the disclosure of tax avoidance schemes (DOTAS) legislation
  • the person is subject to a counteraction notice under the general anti-abuse rule (GAAR)

The tax legislation that deals with accelerated payments refers to a compliance check as a tax enquiry.

Telling you about your accelerated payment

If we need you to make an accelerated payment, we’ll send you an accelerated payment notice which will tell you:

• how much you need to pay and when
• how we’ve worked out the amount you need to pay
• what you can do if you disagree with it

How we work out the amount of an accelerated payment

The amount payable will be the amount relating to the tax advantage that the use of the avoidance scheme tries to achieve. The legislation refers to this as the ‘understated tax’ in cases where there’s a current compliance check, or the ‘disputed tax’ in cases where there’s an open appeal.

We’ll work out the amount to the best of our information and belief. If we do not have all the information we need to work out the exact amount, then the amount shown in the accelerated payment notice may differ from the amount due when your compliance check is complete or your appeal is settled.

We’ll normally repay any amount that you’ve overpaid and any interest that’s due to you on the amount overpaid. We’ll do this if the amount in the accelerated payment notice is more than the amount we find to be due once your compliance check is complete, or your appeal is settled.

Paying what’s due

Payment will be due 90 calendar days after the date you receive the accelerated payment notice. If you make representations objecting to the accelerated payment notice, the date the payment is due may change. You can find more information about this in the section ‘What to do if you disagree with the accelerated payment notice’ on page 8 of this factsheet.

If we send you a follower notice as well as an accelerated payment notice, you should pay the accelerated payment whether or not you’re going to take corrective action. This is because you may be liable to late payment penalties or surcharges for late payment of the accelerated payment. The accelerated payment notice will tell you whether you’ll be liable to penalties or surcharges for paying late.

Problems paying

If you think you may have problems paying, tell us straightaway.

Stamp Duty Land Tax — partnerships and joint purchasers

If the use of the avoidance scheme relates to Stamp Duty Land Tax (SDLT) and you’re either a member of a partnership or a joint purchaser, we’ll send a follower notice and an accelerated payment notice to each responsible partner or joint purchaser. This is because, in law, each responsible partner or joint purchaser is responsible for taking the necessary corrective action and for paying the whole of the accelerated payment. This is explained in more detail below.

The term ‘responsible partner’ means a person who was a partner at the effective date of the transaction that the SDLT is for, and any person that becomes a member of the partnership after that date. However, the legislation does not allow us to recover an accelerated payment from a person who did not become a responsible partner until after the effective date of the transaction.

Follower notice

It’s up to the responsible partners or joint purchasers to decide what corrective action to take and who will take it. We do not need to know the details — as long as corrective action is taken. If corrective action is not taken on time, each responsible partner or joint purchaser will be jointly and severally liable to pay a penalty. This is explained in more detail below, in the section ‘Joint and several liability’.

You can find more information about penalties for not taking corrective action on pages 3 and 4 of this factsheet.

Accelerated payment notice

Each accelerated payment notice will show the whole of the amount due. It’s up to the responsible partners or joint purchasers to decide who will pay the accelerated payment. We do not need to know the details — as long as the accelerated payment is paid in full.

If we charge any penalties for not paying the accelerated payment on time, each responsible partner or joint purchaser will be jointly and severally liable for the whole amount of the penalty. This is explained in more detail below, under the section ‘Joint and several liability’. You can find more information about penalties for not paying an accelerated payment on pages 8 and 9 of this factsheet.

Joint and several liability

For Stamp Duty Land Tax, each responsible partner or joint purchaser is responsible for paying the amount due — including any penalties for paying late. This is known as joint and several liability — sometimes called being jointly and severally liable. What it means in practice for accelerated payment notices and follower notices, is that we can require any one or more of the responsible partners or joint purchasers to pay:

• the accelerated payment
• any penalties for not paying the accelerated payment on time
• any penalties for not taking corrective action on time

Annual Tax on Enveloped Dwellings — partnerships

If the use of the avoidance scheme relates to Annual Tax on Enveloped Dwellings (ATED) and you’re a member of a partnership, we’ll send a follower notice and an accelerated payment notice to each responsible partner. This is because, in law, each responsible partner is responsible for taking the necessary corrective action and for paying the whole of the accelerated payment. This is explained in more detail below.

The term ‘responsible partner’ means a person who was a member of the partnership on the first day in the chargeable period on which the partnership meets the ownership conditions for the purposes of ATED.

Follower notice

It’s up to the responsible partners to decide what corrective action to take and who will take it. We do not need to know the details — as long as corrective action is taken. If corrective action is not taken on time, each responsible partner will be jointly and severally liable to pay a penalty. This is explained in more detail below, under the section ‘Joint and several liability’. You can find more information about penalties for not taking corrective action on pages 3 and 4 of this factsheet.

Accelerated payment notice

Each accelerated payment notice will show the whole of the amount due. It’s up to the responsible partners to decide who will pay the accelerated payment. We do not need to know the details — as long as the accelerated payment is paid in full.

If we charge any penalties for not paying the accelerated payment on time, each responsible partner will be jointly and severally liable for the whole amount of the penalty. This is explained in more detail below, in the section ‘Joint and several liability’. You can find more information about penalties for not paying an accelerated payment on pages 8 and 9 of this factsheet.

Joint and several liability

For Annual Tax on Enveloped Dwellings, each responsible partner is responsible for paying the amount due — including any penalties for paying late. This is known as joint and several liability — sometimes called being jointly and severally liable. What it means in practice for accelerated payment notices and follower notices, is that we can require any one or more of the responsible partners to pay:

• the accelerated payment
• any penalties for not paying the accelerated payment on time
• any penalties for not taking corrective action on time

Penalties for not paying the accelerated payment on time if there’s a current compliance check

If there’s a current compliance check and you do not pay the full amount shown in your accelerated payment notice by the date it’s due, you’ll be liable to a penalty. If we charge you a penalty, you’ll have to pay it as well as the accelerated payment.

If your payment is not made in full on or before:

• the date it’s due, you’ll be liable to a penalty equal to 5% of the amount you still owe
• 5 months of the date it’s due, you’ll be liable to a penalty equal to 5% of the amount you still owe — this is as well as the 5% explained in the bullet above
• 11 months of the date it’s due, you’ll be liable to a penalty equal to 5% of the amount you still owe — this is as well as the 2 earlier 5% penalties

These penalties apply to all the taxes covered by the accelerated payment legislation.

Surcharges and penalties for not paying the accelerated payment on time if there’s a current appeal

Surcharges for accelerated payment notices that relate to Income Tax and Capital Gains Tax

If your accelerated payment notice:

• relates to Income Tax or Capital Gains Tax
• is for the tax year 6 April 2009 to 5 April 2010 or earlier

and you do not pay the full amount shown in the notice, you’ll be liable to a surcharge. If we charge you such a surcharge, you’ll have to pay it as well as the accelerated payment.

If your payment is not made in full:

• within 28 days of the date it’s due, you’ll be liable to a surcharge equal to 5% of the amount you still owe
• on or before 6 months of the date it’s due, you’ll be liable to a further surcharge equal to 5% of the amount that you still owe — this is as well as the 5% explained in the bullet above

Penalties for accelerated payment notices that relate to Income Tax, Capital Gains Tax and Annual Tax on Enveloped Dwellings

If your accelerated payment notice relates to:

• Income Tax or Capital Gains Tax and is for the tax year 6 April 2010 to 5 April 2011 or later
• Annual Tax on Enveloped Dwellings

and you do not pay the full amount shown in the notice, you’ll be liable to a penalty. If we charge you such a penalty, you’ll have to pay it as well as the accelerated payment.

The date on which you become liable to such a penalty is known as ‘the penalty date’. The penalty date is 31 days after the date you were due to pay the accelerated payment.

If your payment is not made in full:

• by the penalty date, you’ll be liable to an initial penalty, which will be equal to 5% of the amount you still owe
• on or before 5 months from the penalty date, you’ll be liable to a further penalty, which will be equal to 5% of the amount that you still owe — as well as the 5% explained in the bullet above
• on or before 11 months from the penalty date, you’ll be liable to a second further penalty, which will be equal to 5% of the amount that you still owe — this is as well as the 2 earlier 5% penalties

General information about surcharges and penalties for not paying the accelerated payment on time

How we tell you about a surcharge or penalty

We’ll send you a notice to tell you how much the surcharge or penalty is and how we’ve worked it out.

Letting us know about any special circumstances

If there are any special circumstances that you think we should consider when calculating the surcharge or penalty, tell us straightaway.

When we will not charge a surcharge or penalty for not paying the accelerated payment on time

We will not charge you any surcharges or penalties for paying your accelerated payment late if you had a reasonable excuse for paying late — as long as you paid without delay once the reasonable excuse had ended.

A reasonable excuse is something that’s stopped a person from meeting a tax obligation on time, which they took reasonable care to meet. This might be due to circumstances outside their control, or a combination of events. Once the reasonable excuse has ended, the person must put things right without any unnecessary delay.

Whether a person has a reasonable excuse depends on the particular circumstances in which they failed to meet the tax obligation, and their particular circumstances and abilities. This may mean that what is a reasonable excuse for one person may not be a reasonable excuse for someone else.

If you think you have a reasonable excuse please tell us. If we accept that you have a reasonable excuse, we will not charge you a surcharge or penalty. If we’ve already charged you a surcharge or penalty for not paying on time, we’ll cancel it.

If you disagree with any surcharges or penalties that we’ve charged

If we charge you any surcharges or penalties for paying the accelerated payment late, you’ll be able to appeal against them if you disagree. You can find out more about appeals in factsheet HMRC1, ‘HM Revenue and Customs decisions — what you can do if you disagree’. Go to www.gov.uk and search for ‘HMRC1’.

Interest for paying late

We do not charge interest for late payment of the accelerated payment itself. However, we do charge interest for late payment of tax — from the date the tax was originally due, until the date it’s paid.

When your tax position is settled, we’ll work out whether there’s any interest for you to pay. For interest purposes, we’ll treat the amount you pay in respect of the accelerated payment notice as if it were payment of the tax. This will mean that interest will stop accruing on the amount of tax equal to the amount of accelerated payment you pay, from the date you pay it.

We may also charge interest on the late payment of any surcharges and penalties.

What to do if you disagree with the accelerated payment notice

There’s no right of appeal against an accelerated payment notice. However, you can make representations to us if you believe that one or both of the following applies:

• the conditions for issuing the notice have not been met — these are shown in the section ‘When we may send an accelerated payment notice’ on page 5 of this factsheet
• the amount shown in the notice is not correct — if this is the case you’ll need to tell us what you think the correct amount is and why

Your representations must be in writing, you must make sure that you send your letter no later than 90 calendar days from the date that you receive the accelerated payment notice. We’ll then consider what you say and let you know our findings. When you write to us, please:

• give us as much information as possible about your representations
• send copies of any documentary evidence that supports your representations

You cannot make representations once the 90 calendar days has passed. This means that, once we’ve told you what our findings are, you’ll not be able to make any further representations if the 90 calendar days has already passed by then. So please make sure that you give us all relevant information when you make your representations.

If you make representations, you cannot ask for postponement of the amount shown in the accelerated payment notice.

However, if you make representations before the date the payment is due, and we do not withdraw the notice, the deadline for paying may be extended. Payment will be due on the later of:

• the due date shown in the accelerated payment notice
• 30 days after the date on which you receive our decision about the representations you made

If the deadline for paying is extended, any penalties for paying late will apply from the extended deadline date.

If you want to settle your tax affairs

If you want to settle your tax affairs once we tell you that we’re going to send you an accelerated payment notice or follower notice, we’ll work with you to settle the compliance check or appeal.

It’s entirely up to you whether you settle your tax affairs. If you do not want to settle, then the compliance check or appeal will stay open.

Your appeal rights for your current compliance check or appeal

When you pay the accelerated payment, even though you may have decided not to take the corrective action referred to in the follower notice, this does not mean that your current compliance check or appeal is settled.

Although you cannot appeal against the accelerated payment notice, the legislation covering accelerated payments does not affect your appeal rights to the tribunals and courts in relation to your tax liability.

This means if you have:

• a current compliance check, you’ll still have your full appeal rights if you do not agree with the outcome of that check
• already appealed against the outcome of your compliance check, an assessment or a determination, you’ll still have your full appeal rights

If you’ve appealed and we had postponed the tax that you’re disputing

If we’ve sent a closure notice in respect of a compliance check or sent an assessment, determination or other type of decision and you’ve:

• appealed against the closure notice, assessment, determination or other decision
• asked us to postpone some or all of the tax in dispute

then the postponement of the tax in dispute is cancelled when we send you the accelerated payment notice. You’ll then have to pay all the tax that had previously been postponed by paying the accelerated payment. This is also the case if you decide not to take the corrective action referred to in the follower notice.

What will happen if you pay the accelerated payment and a court or tribunal later rules that the scheme does produce a tax advantage

If a tribunal or court decides that the scheme does produce the tax advantage, we’d normally repay the amount you’ve paid under the accelerated payment notice, along with any interest that’s due to you.

However, if we appeal against the decision to a higher court or tribunal, we may, in certain cases, also ask for their permission not to repay the amount to you. We would only do this if we believed there was a risk that, if we were successful with our appeal, you would not then pay the amount you owe.

More information

The taxes to which this factsheet relates

This factsheet relates to accelerated payments for Annual Tax on Enveloped Dwellings, Capital Gains Tax, Corporation Tax, Income Tax (Self Assessment) (including Class 4 and most Class 2 National Insurance contributions, except for partners), and Stamp Duty Land Tax (SDLT).

Accelerated payments also apply to:

• Inheritance Tax — if you need to know more about these cases, contact the office that gave you this factsheet
• National Insurance contributions and Income Tax through Pay As You Earn (PAYE) cases — you can find more information about this in factsheet CC/FS26, ‘Avoidance schemes — accelerated payments for Income Tax and National Insurance contributions through PAYE’

The disclosure of tax avoidance schemes (DOTAS) regulations and the general anti-abuse rule (GAAR)

You can find more information online about:

• DOTAS, go to www.gov.uk and search for ‘disclosure of avoidance’
• GAAR, go to www.gov.uk and search for ‘GAAR arrangements’

If you’re not happy with our service

Please tell the person or office you’ve been dealing with. They’ll try to put things right. If you’re still not happy, they’ll tell you how to make a formal complaint.

Our privacy notice

Our privacy notice sets out the standards that you can expect from us when we ask for information or hold information about you. For more information, go to www.gov.uk and search for ‘HMRC Privacy Notice’.