Independent research has been published which considers HMRC’s powers and taxpayer safeguards, specifically in relation to Accelerated Payment Notice (APN) and Follower Notices (FN). The research was undertaken by Ipsos MORI and consisted of a series of interviews with tax agents covering cases between 2012 and 2018.
There were concerns raised about the language and tone of the notices in some cases. Agents felt that communications should use neutral language, as negative tones, or as some
saw, accusations, could generate undue stress for their clients which could reduce their ability and willingness to pay.
Advance warnings of APNs and FNs were viewed as being a valuable part of the process, as it gave both the agent and client time to prepare strategically and financially. When it came to the APNs and FNs themselves agents stressed the importance of making them as clear and concise and concise as possible. A key concern for agents was that an individual would be unlikely to understand the notice, their position or their rights without the help of an agent and some raised questions about whether this was fair for the taxpayer. It was suggested that the legislation providing HMRC with the power should include some protections against this by requiring HMRC to include easy to read summaries in each notice to reduce the reliance on specialist support.
Agents did not always make representations in response to the notices, it being dependent on the wishes of their client. This that did make representations noted that there were often delays in responses for many months. For clients who wanted to resolve the notice, agents said this delay often added to their clients’ anxiety.
“I make representations in nearly every case. I am still waiting for responses to representations from years ago. The issue with this is that clients assume no response means it’s gone away, it’s over”
Consultant, experience of both APNs and FNs
You can read the full research report here
