219 Circumstances in which an accelerated payment notice may be given

Chapter 3
Accelerated Payment

Accelerated payment notices

219  Circumstances in which an accelerated payment notice may be given

(1)     HMRC may give a notice (an “accelerated payment notice”) to a person (“P”) if Conditions A to C are met.

(2)     Condition A is that—

(a)     a tax enquiry is in progress into a return or claim made by P in relation to a relevant tax, or

(b)     P has made a tax appeal (by notifying HMRC or otherwise) in relation to a relevant tax but that appeal has not yet been—

(i)     determined by the tribunal or court to which it is addressed, or

(ii)     abandoned or otherwise disposed of.

(3)     Condition B is that the return or claim or, as the case may be, appeal is made on the basis that a particular tax advantage (“the asserted advantage”) results from particular arrangements (“the chosen arrangements”).

(4)     Condition C is that one or more of the following requirements are met—

(a)     HMRC

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